can I test a product passport now before it becomes mandatory

What you must concretely do

What is expected of you

There is currently no obligation to test a product passport. The ESPR (Regulation (EU) 2024/1781) describes in articles 9 and 10 what a digital product passport must contain and what technical requirements it must meet, but which product groups are dealt with when is worked out per product group according to the prioritisation in article 18. For aluminium semi-finished products, that elaboration does not yet exist. What is stated below is therefore not an obligation but a description of what a company can practically do if it wants to practise now.

Getting ahead is a choice, not an obligation

A company with 10 to 100 employees that now wants to create a test passport does so on its own initiative. There is no article that prescribes this and there is also no deadline to which this is linked. Practically speaking, this means that the choice to test depends entirely on the company's own planning: does the organisation have time and capacity to practise with this now, or is the priority elsewhere. For more information on what exactly can already be done without waiting for final rules, there is an overview on the page what can I already do while the rules are not yet final.

Data that are already available remain relevant

Article 38 of the ESPR describes what data actors in the supply chain must be able to provide once a product passport becomes mandatory: information on composition, origin, processing and the like. For aluminium semi-finished products, many of those data often already exist, for example in alloy certificates, in procurement documentation or in internal quality systems. A company that creates a test passport uses in practice data that it records anyway. This makes a test relatively easy to access: it is not necessary to collect new data, but rather to consider how existing data fit into the structure described in article 10.

The structure of article 10 as a guide

Article 10 sets out requirements for the form and accessibility of the digital product passport, such as the use of a standardised data carrier and the way in which data is made available. For a company wishing to test, this means that a test passport is not simply a loose Excel file, but ideally already takes on the form that the legislation has in mind: a structured whole with a QR code or comparable data carrier that refers to the data. Without an established delegated act for aluminium, the precise content is not yet known, but the main structure from Article 10 already gives a reasonable picture of the direction.

Where things go wrong in practice

Creating a test passport seems straightforward, but in practice companies encounter a few recurring bottlenecks.

Testing with data that is incomplete or not up to date. A test passport is sometimes compiled with data from an old certificate or an outdated specification, which means the test says little about the company's current situation.

Confusion between 'testing' and 'complying with the law'. Some companies believe that a working test passport means they are already compliant once the rules come into force. This is not the case: the final requirements follow from a delegated act that still needs to be published, and this may impose different or additional requirements than those currently being tested.

Testing for one product, while practice consists of dozens of variants. A foundry or profile manufacturer often has many product variants. Anyone who tests with only one article number often discovers too late that the process runs differently once it comes to large volumes and variation. More on this can be found on the page can I register multiple products at once for a product passport.

No internal coordination over who carries out the test. A test passport is quite often put together by one person in the quality department without purchasing, production or sales knowing about it. Once the passport becomes a permanent part of the process, that coordination will be necessary. See also the page on how do I explain to my colleagues what changes with the product passport.

Incorrect expectations about costs. A test is sometimes undertaken with the idea that this is a cheap, non-binding exercise, whereas building a passport — even as a test — requires time and sometimes external support. An indication of where the costs lie can be found on the page what does a digital product passport for aluminium cost.

What you can document now

If you want to test now, you can record a number of things so that the exercise also has value later:

• An overview of which data is already available per product group or alloy, including where this data comes from (supplier, own production, certificate).
• A brief note on which data from Article 38 is still missing and from whom this might need to be requested.
• The chosen test setup: which product or product group was used, which systems or tools were deployed, and which assumptions were made about the form of the passport.
• A list of findings: what worked well, where did employees encounter technical or organisational bottlenecks.
• A schedule for repetition: it is advisable to repeat the test as soon as there is more clarity on the delegated act for aluminium, so that you can compare whether the previous approach still fits.

For companies that prefer to go through these first steps with a fixed structure, the page how do I implement the product passport for aluminium step by step provides an overview of the sequence to follow. It is also useful to determine beforehand whether your own product will fall under the scheme, which is described on the page does the digital product passport apply to my aluminium.

A test passport is therefore not a legal obligation, but a way to become familiar early on with the data, the structure and the internal coordination that will be needed later. Once the delegated act for aluminium has been published, the final date and the precise content of the obligation will be added here.