what is the difference between my technical file and the digital product passport

Two documents, two readers, two purposes

The technical file and the digital product passport resemble each other because they are both built from the same data about the aluminium product, but they are not the same document and were not created for the same audience. The technical file is the substantiation that demonstrates that a product meets the applicable requirements — it exists for supervisory authorities and for the manufacturer itself, to prove that conformity is correct. The digital product passport is a data carrier accessible via a QR code to a broader circle: purchasers, recyclers, market participants further down the chain, and under certain conditions also supervisory authorities and consumers. Both are about the same product, but one document proves something, the other shares something.

For which product and for which purpose this applies

The technical file has long existed as a concept in product legislation and is linked to the requirements concerning ecodesign, performance and information as established per product group — for aluminium semi-finished products this follows from Articles 5 to 7 of the ESPR (Regulation (EU) 2024/1781). The passport is an additional obligation that stands alongside it: Article 10 of the ESPR describes the technical and functional requirements that the product passport must meet, separate from what is in the underlying file. Where this does not apply: the passport does not replace the technical file, and the file does not replace the passport. A manufacturer who has only kept a file does not thereby comply with the passport obligation, and conversely a passport is not a substitute for the underlying conformity assessment. These are two obligations that exist side by side, even though they draw from the same source data on alloy, composition and origin.

What is already established and what is not

A precise date from which the passport becomes mandatory for aluminium products is not yet established. This must still be regulated via a delegated act per product group, and as long as that act has not been published, there is no fixed entry date to mention here. What is established: the requirements for the passport itself — what it must technically be able to do, how it must be accessible — are already laid down in Article 10 of the ESPR. The obligation to maintain a technical file follows from the requirements set per product group on the basis of Articles 5 to 7, and these two tracks — file and passport — therefore proceed at different speeds: one framework is in place, the other is still awaiting product-specific elaboration. Until the delegated act is in place, there is therefore no passport obligation for aluminium, but this says nothing about any other obligations that may already apply.

What this means for your approach

In practice, the sequence is usually as follows: first there is the question of which data is already established, often in internal quality documentation, certificates of origin, or composition data that are already being retained for other purposes anyway. That data forms the basis for both documents. Next, the distinction is mainly a matter of form and access: the technical file remains internal or goes to a supervisory authority, while the passport is intended to be unlocked via a QR code for third parties. This immediately raises a follow-up question that is not trivial: not everything in the technical file needs to become publicly visible via the passport. Anyone wondering whether that tension arises with sensitive production data will find more information on business-sensitive data about aluminium and the disclosure obligation. In addition, it is worthwhile to consider in advance which parties will have access to which part of the passport data, as this varies depending on the role in the chain — this is described under who may view which data from the product passport. Anyone who now starts organizing data on alloy, CO2 emissions per ton, or the share of recycled material is in fact building the content that will later appear in both documents, even if that content appears in the file in a different form than in the passport.

The basis for this: Article 10 alongside Articles 5 to 7

The distinction between file and passport follows directly from the structure of the ESPR. Articles 5 to 7 of Regulation (EU) 2024/1781 regulate the requirements regarding ecodesign and the performance and information requirements that a product must meet — this is the basis on which a technical file is built, further developed per product group in delegated acts. Article 10 of the same regulation separately regulates the technical and functional requirements for the digital product passport itself: how it must be accessible, which data carrier is appropriate for it, and how it is linked to the product. The fact that the passport is in a separate article, apart from the ecodesign requirements, emphasizes that this is an additional obligation and not another name for the same document.

Anyone who wants to start now should first inventory which data are already available about their own aluminium products — think of alloy designation, CO2 figures and the origin of raw materials — and keep them separate from the question of how and to whom those data will be shown in future. Once the delegated act for aluminium has been published, the concrete date and precise scope will be added here.

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

A technical file and a digital product passport resemble each other because they both bundle data about a product, but they serve a different purpose and have a different audience. The technical file is there to demonstrate that a product meets the applicable requirements — that is internal evidence, intended for a supervisory authority that requests substantiation. The digital product passport is there to provide information about the product to everyone in the chain who needs to do something with it: a processor, a recycler, a buyer further down the line. Those who have that distinction in order prevent the same question from having to be answered twice in two different places.

Demonstrating compliance with ecodesign requirements

The ecodesign requirements from Articles 5 to 7 of the ESPR (Regulation (EU) 2024/1781) include both performance requirements (for example something about durability, reusability or the share of recycled material) and information requirements. The technical file is the place where it is recorded HOW those requirements are met: which calculations, tests or declarations underlie this. For a company with 10 to 100 employees, this usually means that existing quality documentation — test reports, supplier declarations, internal measurement protocols — acquires a new function: they are not only kept for internal use, but must also withstand scrutiny if someone from outside asks for them.

Making data available via the product passport

Article 10 of the ESPR describes what the digital product passport must contain and how it must be accessible, including via a data carrier such as a QR code. This is not the place for substantiation, but for the data that the chain needs: which data come in the digital product passport for aluminium therefore stands apart from the question of which underlying test reports exist. For practical purposes, this means that some of the file information does flow through to the passport — for example the alloy designation or the share of recycled material — but in a different, more public form.

Making a distinction between evidence and public information

A technical dossier may generally be more detailed and sensitive than what will appear in the passport, because it serves a different audience. This distinction must be made deliberately: not everything in the dossier automatically belongs in the passport, and not everything in the passport is sufficient as evidence towards a supervisory authority. Companies working with competition-sensitive compositions or recipes quickly run into the question here must I disclose business-sensitive data about my aluminium — a question that can be answered differently for each piece of data.

Ensure both documents align with each other

Because the passport is an extract and the dossier is the substantiation, the two must align: a value in the passport must be traceable to something in the dossier. With aluminium, this is particularly important for CO2 emissions and recycling percentage, for which not every measurement method is readily usable — see according to which method must I measure the values for the passportWhen the method in the dossier does not match what the passport suggests, a discrepancy arises that is difficult to correct once the passport is already published.

Where things go wrong in practice

A common situation is that a company treats the technical dossier as "the source of truth" and assumes the passport will automatically flow from it. In practice, a deliberate selection and translation must be made, and this step is often forgotten or left to an IT supplier without anyone having substantively checked whether the translation is correct.

Another situation: the dossier is updated following a process adjustment (for example, a different alloy or surface treatment), but the passport is not. This directly impacts how often must I update the data in the product passport — the dossier may be internally current while the passport, already with the customer or importer, shows outdated information.

Also problematic: companies assume that what is confidential in the dossier will remain so in the passport. Without separate assessment per piece of data, there is a risk that sensitive recipe or process information becomes visible to parties who, according to who may view which data from the product passport are entitled to access it, but whom the company would not have wanted to share it with.

A fourth situation arises with surface treatments: the dossier often contains extensive process parameters, while the question of whether and how this should be included in the passport — see must I report the surface treatment of aluminium — must be answered separately. Those who fail to do so either transfer too much process detail, or forget a piece of data that is actually expected.

Finally: companies that supply internationally sometimes draw up the passport in a single language because the technical dossier is also in that language, without checking whether this aligns with what is requested under in which language must the data in the product passport be presented.

What you can document now

A list of which data from the technical dossier is intended for internal evidence, and which is intended to flow through to the product passport.
A fixed control point at which dossier and passport are compared alongside each other with each change in composition, alloy, or process.
An internal agreement on who is responsible for the "translation" between dossier and passport, so that this does not implicitly fall to a software supplier.
A list of data marked as commercially sensitive, with the reason why, so that this assessment is repeatable and traceable.
Documentation of the measurement method used per piece of data (for example, for CO2 emissions or recycling percentage), so that dossier and passport are based on the same substantiation.
Version management that records when the dossier was updated and when that change was (or was not) implemented in the passport.

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.