must I include information about repair and restoration of aluminium in the passport
Repair information is not a standard section, but follows from the product group
There is no general rule in the ESPR stating that every digital product passport must contain information about repair and restoration. Article 10 of the ESPR (Regulation (EU) 2024/1781) lists what a passport may contain in any case, but which data categories become mandatory for a specific product is determined per product group in a delegated act pursuant to Articles 5 to 7. For aluminium semi-finished products, that act does not yet exist. Once it appears, it will also specify whether and how repair or restoration information becomes a mandatory component.
Who this is relevant for and what it is not
Repair information as a theme in the ESPR was conceived primarily with products in mind that are repaired as a whole unit: appliances, machines, furniture, textiles. For aluminium semi-finished products — profiles, sheet, castings, packaging material — the situation is different. These products are rarely "repaired" in the sense of a repair manual; they are processed, worked, coated or melted down at the end of their service life and reused. What may become relevant for aluminium is information related to circularity, such as material origin and the share of recycled aluminium — that is different data from repair information, and the process for this is described on the page about how you demonstrate the share of recycled aluminium. For those wondering what actually does go in the passport as standard, the overview of which data in the product passport for aluminium appear provides a more complete picture than this page on repair alone can give.
That said, a delegated act for aluminium could in theory include something on restoration of surface treatment, remelting, or other forms of material recovery that are specific to metal semi-finished products. That is not yet known; it will only become clear when the product group-specific rules are in place.
The date is not yet fixed
There is no published delegated act for aluminium semi-finished products yet, and therefore no established content for what exactly must go in the passport — including the question of whether repair information will be part of it. The workplan for ecodesign and energy labels 2025-2030 of the European Commission lists aluminium as one of the product groups for which a delegated act is in preparation, with 2027 as the expected publication date. Until that act is in place, there is no obligation for aluminium to have a digital product passport and therefore no obligation for a specific repair information section. As soon as the act is published, that date and the content will be updated here.
What this means for your preparation
Anyone working on a product passport now should best start with the data that is already clear to be relevant: origin and composition of the material, the alloy designation, CO2 emissions per tonne, and the share of recycled material. There is a separate explanation for how the alloy and the EN-AW designation are established. Repair or restoration information is not currently something that is settled for aluminium, so it is practical not to regard that section as mandatory for now, but to keep it in mind when structuring the data. A passport system that is flexible enough to add an extra data field later will save work once the delegated act is in place.
More important at this moment is getting the data in order that will almost certainly come back, such as origin, composition and any surface treatment — see also the explanation on whether surface treatment of aluminium must be reported. Anyone who already records this basic data in a structured manner will be well-positioned when it becomes clear which additional categories, potentially including repair information, become mandatory.
What this is based on
Article 10 of the ESPR (Regulation (EU) 2024/1781) describes the general requirements that a digital product passport must meet, such as accessibility, structure and linking to a unique identification code, but does not specify which substantive data categories are mandatory for each product. That specification follows from Articles 5 to 7 of the same regulation, which empower the Commission to lay down, per product group, via a delegated act, which information requirements apply — including any requirements regarding repair, maintenance or recovery. For aluminium semi-finished products, that delegated act does not yet exist, which means there is also no article or annex that specifically prescribes repair information for this product.
What to do
For now it is practical to set aside repair information as a mandatory component and focus attention on the data that are already considered likely to be relevant — origin, alloy, CO2 emissions and recycled content — and to structure the data system in such a way that an additional field can later be added without much effort. Once the delegated act for aluminium is published, this is the page where you can read whether and how repair information has actually become a mandatory component.
What this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 10 (requirements for the digital product passport)
- Regulation (EU) 2024/1781 (ESPR), Articles 5 to 7 (ecodesign requirements, performance and information requirements)
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 ESPR allows the precise content of the product passport per product group to be specified in a delegated act. For aluminium semi-finished products, that act does not yet exist — the date for it is, as explained elsewhere on this platform, not yet fixed. What is already fixed are the general provisions: Article 10 of the ESPR (Regulation (EU) 2024/1781) describes what a digital product passport must generally be able to contain, and Articles 5 to 7 describe the types of information and performance requirements that the Commission can impose per product group. Repair and recovery are substantively part of that, but whether and how that becomes mandatory for aluminium semi-finished products must still be shown by the delegated act.
Repair information as a possible category
Article 7 mentions durability, reusability and repairability as subjects on which information requirements can be imposed. For physical products with moving parts or replaceable components, repair information is obvious: how do you disassemble it, which parts are replaceable, which tools are needed. For aluminium semi-finished products — profiles, sheet, castings, packaging material — that is different. A profile is rarely "repaired" in the sense of replacing parts; more relevant is often information on reprocessing, welding, coating or pressing. For a company with 10 to 100 employees, this means above all: do not yet specify what is not being asked for, but do check what technical information on finishing and repair already exists within the company.
Alignment with existing technical information
Many manufacturers and importers already have documentation that relates to repair: welding specifications, guidelines for thermal post-treatment, coating specifications, or instructions for updating a damaged surface. In practical terms, this means it may be advisable to inventory this documentation, even though it is not yet known whether and in what form it will later be required in the passport. Whoever now already the technical file and the digital product passport side by side reveals that repair and finishing information is often already in the technical file, but is not yet structured for reuse in a passport.
Coherence with other passport data
Repair information is not separate from the rest of the passport. Whether something as "repaired" aluminium still represents the same CO2 value or the same recycling percentage relates to the question of how you demonstrate the CO2 emissions per tonne of aluminium and how you demonstrate the share of recycled aluminium. A company that is already thinking about repair information now would be wise to view this in connection with the other fields that the passport will probably contain, rather than as a separate subject.
Where things go wrong in practice
A foundry assumes that repair information will be mandatory anyway, because this has been the case with other product groups (such as electronics) for some time, and invests time in drawing up repair instructions that are never requested as such — while more relevant information, such as the alloy designation, is not yet in order.
A profile manufacturer confuses repair information with warranty or maintenance terms. These are contractual agreements with the customer, not passport data; the passport concerns material properties and origin, not commercial warranties.
A packaging aluminium company thinks that "repair" is not applicable to their product and omits the subject entirely, while post-processing instructions (for example for restoring a damaged coating on a semi-finished product that is further processed) may indeed become relevant.
A company records repair information as free text in a PDF, without considering what language may be required for it later. With a passport that is consulted internationally, it is useful to know in advance in which language the data in the passport must be recorded, so that repair instructions do not have to be translated afterwards.
An importer takes repair information from the foreign manufacturer literally, without checking whether it complies with European requirements for measurement methods and reporting — whereas the question according to which method the values for the passport must be measured is decisive for what is usable at all.
What you can document now
- An overview of existing documentation on post-processing, repair and maintenance of your own aluminium product, even if this is not yet passport-ready.
- Welding specifications, coating instructions and guidelines for thermal post-treatment, linked to the specific alloy; this aligns with how the alloy and the EN-AW designation are recorded.
- Information on the surface treatment and the options for restoring or replacing it, relevant to the question of whether the surface treatment of aluminium must be reported.
- A contact point or process within the company responsible for keeping this information up to date, so that when the delegated act is published, it can be acted upon quickly.
- A note on each document about the source and date, so that afterwards it can be traced which information still needs to be updated — a practice that also aligns with the broader question how current the data in the product passport must be.
Once the delegated act for aluminium semi-finished products is published, this will be supplemented with details on whether and in what form repair information is exactly requested.
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 2026-09-05. Is something incorrect? Let us know — corrections are prioritised.