How do I tackle the product passport for aluminium step by step?

Five steps: from product data to QR code on aluminium

The digital product passport for aluminium comes down to a fixed sequence in practice: collecting data, having the data compiled into a passport, linking the passport to a data carrier, and affixing that carrier to or with the product. Article 9 of the ESPR (Regulation (EU) 2024/1781) describes the passport itself as a collection of product data made accessible via a data carrier, and Article 10 sets out the requirements that passport must meet — who supplies which data, how long it must remain available, and who is permitted access. For a manufacturer or importer of aluminium semi-finished products, this means the process fundamentally always follows the same steps, regardless of whether it concerns profiles, castings or packaging aluminium. The precise content of the passport — which data are mandatory for aluminium specifically — will emerge from a delegated act, but the approach is already established in the framework regulation.

Which aluminium products this applies to, and which do not yet

This step-by-step guide is written for semi-finished aluminium products: profiles, castings and packaging material, supplied by a manufacturer or importer placing these products on the European market. It concerns the approach based on the ESPR as the framework regulation; it does not apply to product groups for which a more specific passport scheme already exists, such as batteries, which fall under a different regulation with its own requirements and timeline. It also does not constitute confirmation that a passport is already mandatory for a specific aluminium product — that obligation only arises with the delegated act that specifically sets out the requirements for this product group. Until that time, this step-by-step guide is primarily a preparation: the data that will be needed later can already be organised without there being a legal obligation to publish the passport.

When this becomes mandatory is not yet certain

There is no established date yet on which the product passport for aluminium becomes mandatory. According to the ESPR work programme 2025-2030, the delegated act for this product group is expected in 2027; only after publication of that act will it become clear from which point manufacturers and importers must actually comply with the requirements. Until that publication, the framework regulation applies, but without the product-specific specification, there is as yet no concrete obligation for aluminium to maintain a passport. Once the delegated act is published, the date will be stated here as it has actually been established — an estimate in advance would add nothing to what is already known.

This is what the process looks like in practice

The first step is to inventory the data that a product passport will need: alloy composition, material origin, recycled aluminium content, and data on processing and treatment. This can already be recorded before there is a legal obligation, simply because this data often already exists somewhere in the organisation but has not yet been consolidated. The second step is to determine which part of the assortment will fall under the delegated act — not every product necessarily needs to have the same requirements. The third step is to choose a way to convert the data into a passport that complies with the requirements of Article 10: a format that can be consulted by the right parties, and that remains accessible for the required period. The fourth step is to apply the data carrier — in practice a QR code — on or with the product, so that the link between the physical product and the digital passport is established. The fifth and ongoing step is to keep the data up to date: a passport that was accurate when created but is never updated loses its value as a reliable source. Alupas.eu supports this process by compiling the passport from the data supplied by the manufacturer or importer, hosting it for ten years, and providing the QR data carrier — the substantive requirements for that data follow from the legislation itself, not from the platform.

The legal basis: Article 9 and Article 10 of the ESPR

This approach follows directly from the ESPR. Article 9 introduces the digital product passport as an instrument and links it to a data carrier on the product. Article 10 sets out who is responsible for providing data, how long it must remain accessible and who has access to it. Both articles form the framework within which later, product-specific rules — such as the delegated act for aluminium still to be published — take their concrete form.

Anyone who wants to start now can begin organising material and origin data without waiting for the delegated act; that work will be necessary anyway and does not need to wait for a definitive date.

What this is based on

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 digital product passport will not arrive all at once. Articles 9 and 10 of the ESPR (Regulation (EU) 2024/1781) describe what a product passport must contain and how it must be accessible, but the specific requirements per product category — including aluminium semi-finished products — will only be laid down in a delegated act. Until that is in place, a company can already put its affairs in order. The steps below are a practical division, not a legal sequence.

Knowing which products will fall under the regulation

For a profile manufacturer, foundry or packaging aluminium producer, the first question is which product lines will need a passport in the future. Not every semi-finished product will be designated on the same timescale or with the same requirements. A company with ten to one hundred employees usually has a limited number of main product groups — that makes this inventory manageable, provided someone tackles it systematically rather than ad hoc. A good starting point is the question Does the digital product passport apply to my aluminium?

Knowing which data will be needed

Article 10 lists categories of information that a passport can contain, such as origin, material composition and data on repair or recycling. For a medium-sized company, this mainly means: checking which of that data already exists somewhere (in the ERP system, at the smelter, at the alloy supplier) and which is not yet systematically recorded. This is not a legal exercise but a data inventory, often the work of quality or procurement together.

Knowing who will supply the data

With aluminium, the origin of the material — primary or secondary, from which smelter, which alloy additions — is usually not fully known in-house. Part of the data must come from the supplier. For a company of this size, this means that agreements are needed with suppliers about which data they provide and in what form. Those who record this now do not have to do it under time pressure later.

Knowing who will technically handle the passport in the future

Article 9 requires that the passport is digitally accessible via a data carrier, such as a QR code. For a production company, this is usually not a task to build itself; it is work for a platform that compiles the passport, hosts it and supplies the data carrier. What a company does need to know itself is which data it provides and how long that data must be kept.

Where things go wrong in practice

A few situations keep coming up among companies tackling this subject systematically for the first time.

First: the assumption that it is still too early to do anything because the date is not yet set. That is correct for the obligation itself, but not for the preparation. Data inventory and supplier agreements take time, and that time is available now.

Second: data that does exist, but scattered across different departments or systems without anyone having an overview. During an inspection or when compiling the first passport, it turns out that no one knows exactly where which piece of data comes from.

Third: suppliers who do not know that data will be requested from them in the future, and are therefore not prepared when the time comes. A foundry that purchases alloys from multiple smelters runs into this more quickly than a company with one fixed supplier.

Fourth: staff who only hear about the product passport when a customer or regulatory authority asks for it. That leads to unnecessary uncertainty on the shop floor, whereas explanation beforehand can prevent that — see also how do I explain to my colleagues what changes with the product passport

Fifth: companies that think one passport template will suffice for all product lines, while profiles, castings and packaging aluminium have different data and different supply chains. Those who want to register multiple products at the same time are well advised to check in advance can I register multiple products at once for a product passport

What you can document now

A number of things can already be recorded on paper or digitally now, so that the company does not start from scratch as soon as the delegated act is in place:

An overview of product lines and which of these are likely to fall under the regulation, including the reasoning why.
An inventory of existing data per product: composition, origin, alloy, any recycling information.
Agreements with suppliers on which data they can provide and in what format — this can be appended to existing procurement contracts.
A designation within the company of who is responsible for maintaining this data, even if the platform ultimately compiles the digital product passport.
A note on the expected costs of participation, as a basis for internal decision-making — an initial indication of this can be found at What does a product passport for aluminium cost?
A test setup, once that option is available, to see how your own data relates to a digital product passport format — more information on this can be found at can I test a product passport now before it becomes mandatory

Anyone building this step by step does not need to wait until the date is confirmed to be well prepared. The background on why that date is not yet fixed — and what a delegated act does in this exactly — is described at What is a delegated act and why does it determine what I must do?

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.