a product passport must be included with loose aluminium spare parts

What you must concretely do

What is expected of you

The ESPR (Regulation (EU) 2024/1781) sets out in article 1 that the regulation establishes a framework for requirements applicable to products, with the aim of making products more sustainable and ensuring that information on their environmental performance becomes available — including the digital product passport. Article 1 makes no general distinction between a complete product and a spare part supplied as a replacement. Whether a product passport is concretely required for a spare part depends on the delegated act drawn up for the relevant product group: that act determines which products within a group fall under the obligation. For aluminium semi-finished products, that act does not yet exist, so it is not yet clear whether and how spare parts are included in it.

Determining whether the component falls within the product group

A spare part made of aluminium — think of a loose profile, a casting or a container supplied as a replacement — must first be recognised as falling within a product group regulated by the ESPR. Article 2 of the ESPR provides the definitions that play a role in this, such as what is understood by "product". For a company of 10 to 100 employees, this means it is useful to check whether their own production actually falls within the scope of the regulation, which is covered in more detail on the page on which products from the aluminium sector fall under the ESPR. A spare part generally shares the fate of the main product for which it is intended: if the original profile or casting falls under a delegated act, it is obvious that the replacement component will be viewed in the same category.

Making the distinction between semi-finished product and finished component

Many aluminium spare parts leave the factory as a semi-finished product: a profile cut to size, a casting without further processing. Whether a passport is already required for it is linked to the question of when a semi-finished product falls under the obligation and when the finished product bearing it does. That distinction is explained on the page on whether a product passport is already required if the aluminium is still a semi-finished product. For a company supplying spare parts as a semi-finished product to an assembly company, it can make a practical difference who in the chain will then be responsible for creating and supplying the passport.

Documenting the origin of the aluminium

Spare parts are often made from a different alloy or casting batch than the original part, and sometimes from recycled material. Article 2 of the ESPR contains definitions that are relevant to how origin and composition are recorded. Whether it concerns primary or secondary aluminium is a distinction that can have implications for the data that will eventually appear in the product passport, as described in more detail on the page about whether it makes a difference whether aluminium is primary or secondary. For a medium-sized company that produces spare parts from varying batches of scrap or ingots, this means that careful registration of origin per production batch may become relevant in time, even though the precise requirement is not yet established.

Following the delegated act for the own product group

Because Article 1 of the ESPR sets the framework but the concrete obligation per product category is elaborated in a delegated act, following that act is the way to know when and how spare parts are exactly affected. What a delegated act entails and why it is decisive is explained on the page about what a delegated act is and why it determines what must happen. For a small business, this is mainly a matter of periodically checking for news, rather than setting up a complete passport system now for an obligation that is not yet established.

Where things go wrong in practice

A first situation is that a spare part is seen as "just a piece of aluminium" and therefore overlooked, while the original product for which it is intended falls within a regulated product category. The part may then be subject to the same obligation, even though it appears to be administratively separate.

A second situation arises when a company supplies spare parts to multiple customers who process the part in different end products. Without clear agreement, it is not established who is responsible for compiling the product passport: the supplier of the semi-finished product, or the party that incorporates the part.

A third situation is the absence of origin registration. Spare parts are often made in smaller series, sometimes from remaining batches or mixed material, making it impossible to reconstruct afterwards which alloy or what proportion of recycled aluminium was used.

A fourth situation is that a company thinks spare parts are automatically excluded because they are "not the main product", and therefore does not adapt when the delegated act for its own product category is published.

A fifth situation is confusion about the scope of its own obligation: smaller suppliers of spare parts sometimes assume that company size by definition provides exemption, while that depends on what is determined in the regulation itself about small businesses, as discussed on the page about whether the product passport also applies to small companies.

What you can document now

• An overview of which spare parts are produced and for which main product or product category they are intended.
• Origin data per production batch: alloy, proportion of primary or secondary aluminium, and any supplier of the base material.
• Agreements with customers about who is responsible for compiling and submitting the product passport when the spare part is supplied as a semi-finished product.
• A fixed procedure for monitoring new delegated acts that are relevant to its own product category, so that a change does not go unnoticed.
• Internal documentation about the distinction between semi-finished product and finished part within its own production process, as a basis for the moment when a passport actually needs to be created.