How does the QR code for the digital product passport get onto my aluminium?
On the product, the packaging, or the documentation
The QR code — called a "data carrier" in the ESPR — is placed on the product itself, on the packaging, or in the accompanying documentation, depending on what the product-specific rules for aluminium will establish on this matter. Article 11 of the ESPR (Regulation (EU) 2024/1781) describes the technical requirements that this carrier must meet, regardless of which medium it ultimately appears on: it must remain legibly readable throughout the period in which the product is on the market or remains in use, be linked to a unique product identification, and be readable with a generally available device such as a smartphone camera. Who exactly applies the code and on which physical medium — an engraved marking, a label on a coil, a label on the packaging of profiles, or an entry on the delivery note — is not laid down in the ESPR itself, but will be worked out per product group in a delegated act. Alupas.eu compiles the passport and supplies the QR data carrier; the physical application of it to the product remains the responsibility of the manufacturer or importer.
Who this applies to, and what does not
These requirements are written for manufacturers and importers of products that fall under a product-specific ESPR regulation; for aluminium half-finished products — profiles, castings, packaging aluminium — that regulation does not yet exist. What is already established, however, is the generic framework from Article 11: the technical requirements for the carrier itself, separate from the question of which product must eventually carry it. What is not covered here is traditional product labelling such as energy labels or CE marking; these fall under other regulations. Articles 16 and 17 of the ESPR also govern something different from the QR code of the digital product passport: they regulate physical labels that say something about the sustainability performance of a product, and the prohibition of labels that resemble them without meeting the requirements. The QR code of the digital product passport has its own article and its own function: to provide access to data, not to express a sustainability claim itself.
The date is not yet fixed
There is no established date yet on which aluminium half-finished products must actually carry a digital product passport with a QR code. According to the ESPR Work Plan 2025-2030, the delegated act for this product group is expected in 2027; after publication of such an act, there is usually still a period before the obligation actually takes effect. Until that act is in place, there is no legal obligation for aluminium to apply a data carrier. However, the generic technical framework of Article 11 is already established, so that the requirements for the carrier itself — readability, linkage to a unique identification, accessibility — will not change once the sector-specific act is published. Once that act is published, the date on this platform will be updated.
How this is being prepared in practice
Anyone currently working on this subject is well advised to follow the sequence in which the obligation will eventually work. First comes the product data: information about the composition, origin, processing and properties of the aluminium, supplied by the manufacturer or importer. Next, the passport is compiled from this data and hosted for ten years, so that the data remains accessible as long as the product is in circulation. Only then comes the physical step: the QR data carrier is supplied, and the manufacturer or importer determines — within the requirements that the delegated act will then set — on which physical medium the carrier is placed. For aluminium profiles, an engraved or embossed marking is obvious given the long service life; for coils or packaging aluminium, a label or print may be more appropriate. Which choice ultimately meets the requirements depends on what the sector-specific rules prescribe once they are published.
The basis: Articles 11, 16 and 17
This explanation is based on three articles from the ESPR (Regulation (EU) 2024/1781). Article 11 describes the technical design and functioning of the digital product passport, including the requirements for the data carrier through which the passport is made accessible. Article 16 concerns labels that display the sustainability performance of a product, and article 17 prohibits labels that resemble them without meeting the associated requirements — both articles thus concern a different type of label than the QR code of the passport, but are relevant to see where the boundary lies between "label" and "data carrier for the passport". Which delegated act will concretely apply these general requirements to aluminium semi-finished products has not yet been published at the time of writing.
Those who wish to be prepared now can start by putting in order the product data that will later need to go into the passport — composition, origin, processing steps — so that this data is ready as soon as the sector-specific rules for aluminium are published. Alupas.eu updates this page as soon as there is news about the delegated act.
What this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 11 (technical design and operation of the digital product passport)
- Regulation (EU) 2024/1781 (ESPR), article 16 (labels) and article 17 (imitated labels)
The regulation itself is on EUR-Lex. We refer per statement; you do not have to take our word for it.
What you must concretely do
What is expected of you
The QR code as access point, not as storage
Article 11 of the ESPR (Regulation (EU) 2024/1781) describes the digital product passport as a set of data accessible via a data carrier — the QR code itself contains no product information, but points to where that information is located. For a manufacturer or importer of aluminium semi-finished products, this means that the QR code on the profile, coil or packaging is simply a link to an online passport. For a company with 10 to 100 employees, this is usually not a technical development carried out in-house, but something that is purchased from a platform that handles the link between product and QR code. What is important to arrange in advance is how the identification of each product or batch proceeds exactly, because the QR code must point to the correct passport — how do I give each product a unique identification code? describes what choices are involved.
The data carrier must be physically present on the product
Article 11 stipulates that the data carrier must be on the product itself, on the packaging, or in the accompanying documentation, depending on what the delegated act determines for the product group. For aluminium profiles that are supplied in coils, bundles or pallets, the practical question is where exactly that QR code goes: on a label attached to the bundle, printed on the packaging, or sent along as a document. This is a choice to be determined per product group in the delegated act that is still to come, but the preparation — which carrier is practically feasible in an extrusion or casting production process — can be mapped out earlier.
Recognisability and distinction from other labels
Articles 16 and 17 of the ESPR deal with labels in general terms and with preventing labels that imitate a product passport without there actually being a passport behind it. For a company that already works with quality certificates, CE marking or its own batch labels, this means that the new QR code cannot simply be stuck among the existing labels without distinction. The QR code for the product passport must be demonstrably recognisable as such, and must not be confused with internal administrative codes or other markings on the same piece of aluminium.
The code must continue to work, even after change of ownership or system
A QR code that today points to a working passport must continue to do so over time. For aluminium semi-finished products that are sometimes kept in stock for years or only processed late in a final product, the duration of availability is relevant — how long must a product passport remain available? elaborates on this further. This also touches on the question of what happens if the company behind the QR code no longer exists, which is described separately.
Where things go wrong in practice
The QR code is printed in a location that disappears during processing. With extrusion profiles that are cut to size, a label at the end of a length often disappears in the first processing step. If the QR code is not also on the packaging or in the accompanying papers, there is no access to the passport after sawing.
One QR code for a pallet with products that actually each need their own passport. With packaging aluminium that is delivered as a coil but ultimately processed into loose products, confusion arises about whether the code belongs at batch level or at product level. This is related to the question of whether aluminium is registered per batch or per piece, which is not filled in in the same way for every semi-finished product.
The QR code is confused with an existing quality label or internal article code. Some companies stick the new code next to an existing CE label or their own batch number without making clear which code points where. That is precisely the situation that Article 17 of the ESPR wants to prevent: a label that appears to be a product passport, or appears to be without being one.
The code is printed on a label that does not withstand the conditions in the foundry or rolling process. Heat, oil or mechanical wear during further processing can make a QR code unreadable before the product reaches the end user. What practically happens with access to the product passport in that case is described in what happens if the QR code on aluminium becomes unreadable.
No coupling between the QR code and the company's own production system, which means each product passport is created manually. For companies that produce hundreds or thousands of batches per year, manually coupling QR codes to product passports is error-prone and time-consuming. Whether and how this can be coupled to an existing ERP or inventory system is a question that must be answered early in the process, not afterwards.
What you can document now
- An overview of where the QR code is physically applied per production line — on the profile itself, on the bundle packaging, or in the accompanying documentation, with a reason why that location was chosen.
- A description of the labelling or printing process, including the material of the data carrier and the expected conditions to which it will be exposed (heat, moisture, mechanical stress).
- Agreements with the QR code or platform supplier about what happens in case of damage, replacement or reissuance of a label.
- An established structure for identification codes, so that each QR code uniquely refers to one product passport without overlap with internal article numbers — the approach for this aligns with what is described about unique identification codes.
- A choice regarding batch or unit registration, documented per product group, so that in the event of an inspection or inquiry from a customer it is clear what level of detail the QR code provides.
- A note on the distinction from existing labels, so that it is demonstrable that the QR code of the product passport cannot be confused with other markings on the same product, in line with Article 16 and Article 17 of the ESPR.
Alupas.eu maintains templates for these records and updates the content as soon as the delegated act for aluminium semi-finished products is published and establishes specific requirements for the data carrier.
This is not legal advice. This page provides general information on the legislation that this platform covers. We do not know your situation. If in doubt about your own case, consult a lawyer or the competent supervisory authority.
Written with AI based on the sources above, checked by a human on 2026-08-22. Is something not right? Let us know — corrections are prioritised.