What does the digital product passport mean if I sell aluminium via an online marketplace?

The marketplace and the seller share responsibility

Anyone selling aluminium products via an online marketplace cannot avoid the digital product passport — but the question of who takes which action shifts somewhat. The manufacturer or importer remains responsible for compiling the passport itself. Additionally, separate obligations apply under the ESPR (Regulation (EU) 2024/1781) for the parties that subsequently resell the product: distributors and traders (articles 30 and 31), and for the marketplace that facilitates the sale (article 35). In practice, this means that both the party offering on the marketplace and the marketplace itself have a role in keeping the passport information visible and accessible to the buyer.

Who this applies to, and who it does not

These obligations concern three different roles, and it is worth keeping them separate. First, the manufacturer or importer: they compile the passport and provide the QR data carrier, regardless of which channel the product is eventually sold through. Second, the distributor or trader: this is the party that resells the aluminium product without being a manufacturer or importer themselves — for example, a reseller who purchases profiles or semi-finished products and offers them via their own webshop or via a marketplace. Articles 30 and 31 of the ESPR concern this role. Third, the online marketplace provider itself: the platform on which multiple sellers display their offers. Article 35 specifically addresses those platforms.

This distinction is usually relevant for the target group of alupas.eu — profile makers, foundries and packaging aluminium producers — in the first or second role, not the third: most companies are not themselves a marketplace, but may sell via one, or have their product sold via a trader. What does not fall under this: purely informational product pages without a purchase option, and the company's own website that does not have a marketplace function (ordinary rules for manufacturers apply there, not the additional rules for platforms).

When this comes into force is not yet fixed

For aluminium, the date on which the product passport becomes mandatory is not yet final. According to the ESPR work plan for 2025-2030, the delegated act for aluminium is expected around 2027; the obligation itself would subsequently, as expected, come into force around 2029. Once the delegated act is published, that date will be stated here. The obligations for distributors, traders and marketplaces from articles 30, 31 and 35 are linked to that same date: they apply from the moment the passport for the relevant aluminium product becomes mandatory, not before. Until then, nothing changes in what is legally required on the basis of this regulation for sales via a marketplace.

What this concretely means, in the order in which you address it

Anyone selling via a marketplace would do well to first determine their own position: does the company act as a manufacturer or importer of the aluminium product, or as a reseller offering a product from someone else? If it is a case of manufacturer or importer status, the responsibility for compiling the passport and providing the QR data carrier lies with your own company, regardless of the sales channel.

If it is a case of resale — offering aluminium products that have been manufactured or imported by another company — attention turns to the question of whether the passport is already present on the purchased product. This means checking whether the supplier has affixed the QR data carrier to the product, packaging or accompanying documentation before the product is placed on the marketplace.

When placing the offer on the marketplace itself, it is then about accessibility: the buyer must be able to consult the passport information before the purchase is completed, so the QR code or the link to the passport belongs in the product listing, not only in the box sent after purchase. Anyone who operates their own marketplace on which third parties offer aluminium products must also take into account their own obligations as a platform: these concern facilitating that visibility and cooperating with supervisory authorities if an offer does not meet the requirements.

Finally, it is practical to clarify first in case of doubt about your own role — manufacturer, importer, distributor or dealer — because the obligation arising from the ESPR depends on that, not on the chosen sales channel.

Where this follows from: articles 30, 31 and 35 ESPR

The obligations of distributors and dealers are set out in articles 30 and 31 of Regulation (EU) 2024/1781 (ESPR). The additional obligations for providers of online marketplaces and search engines are set out in article 35 of that same regulation. Both are part of the broader system around the digital product passport and apply in conjunction with the delegated act that is specifically drawn up for aluminium.

What to do now

First determine whether your own company acts as a manufacturer, importer or reseller for the aluminium product in question, and keep an eye on when the delegated act for aluminium is published — that date will appear on this page as soon as it is known. Anyone already selling via a marketplace can start mapping which product listings will need a QR data carrier, so that this step is not carried out hastily afterwards.

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

Aluminium semi-finished products offered via an online marketplace are subject to the same digital product passport obligations as aluminium sold via a company's own webshop or directly to customers. The sales channel does not change whether a passport is required. What does change is who must pay attention to what: the marketplace operator assumes its own role alongside that of the seller itself.

What is expected of you

As a selling party, you remain responsible for the passport yourself.

Selling via a marketplace is a distribution choice, not a change in the chain of responsibility. A company that offers aluminium profiles, castings or packaging material via a marketplace is still a manufacturer, importer or distributor according to the standard classification — and that role determines which obligations apply, as described on who is responsible for the digital product passport of aluminium?. If you are unsure about your own position in that classification, you will find guidance on am I an importer or manufacturer according to the ESPR?. A marketplace is a sales outlet, not a party that assumes the obligation.

The marketplace itself assumes its own obligations under Article 35 ESPR.

Article 35 of the ESPR (Regulation (EU) 2024/1781) sets out obligations for online marketplace operators and search engines regarding the digital product passport. This means that the marketplace on which aluminium is offered itself also assumes a role in the digital product passport — separate from what the seller does. For a company with 10 to 100 employees selling via such a platform, this means in practice that the marketplace may request the passport or QR code to be supplied before a listing can go online, or that a listing without a valid passport may be refused or removed. The marketplace's obligation does not release the seller from their own obligation; it comes in addition to it.

Distributors selling via a marketplace retain their own verification obligation.

Anyone who resells aluminium from a third party via a marketplace is, under the ESPR, a distributor or trader. The obligations that come with this — verifying that the passport is present and not supplying further without it — are described in Articles 30 and 31 of the ESPR and are further detailed on what obligations does a distributor or trader of aluminium have?. Using a marketplace as a sales channel does not change this verification obligation: the question of whether the passport is there must still be answered before the product is offered, marketplace or not.

When selling under a own brand via a marketplace, the brand owner obligations apply in full.

A company that offers aluminium under its own brand via a marketplace is treated as a manufacturer under the ESPR, even if the physical production takes place elsewhere. The obligations that come with this are the same as when selling through other channels; the overview on I sell aluminium under my own brand — what obligations do I have? goes into more detail about what this role entails. In this case, the marketplace is only the point of sale; responsibility for the passport rests with the party whose brand appears on the product.

Where things go wrong in practice

The assumption that the marketplace will take care of the passport. Some sellers assume that a large platform with its own compliance department will automatically solve this. Article 35 ESPR requires the marketplace to assume its own role, but this is a controlling or facilitating role — not a role in which the marketplace draws up the passport on behalf of the seller or collects the underlying data.

A listing that is already online without the passport being ready. When selling via a company's own webshop, a business immediately notices when something is missing. On a marketplace with automated listing uploads, a product can go live without anyone having checked whether the QR code has been linked yet.

Confusion about who the manufacturer is in the case of dropshipping via a marketplace. In dropshipping constructions, the marketplace account sometimes sells aluminium products that are shipped directly from a manufacturer or importer outside the EU. Who in that chain is responsible for the passport depends on who qualifies as a manufacturer or importer — a question that is elaborated on my manufacturer is located outside the EU — who arranges the product passport then?.

One marketplace listing for products with different origins. A single marketplace listing is sometimes used for a product group that in reality comes from different suppliers, each with different composition data. The passport belongs to a specific product with specific data, not to a generic listing.

No action taken when a listing is removed due to missing passport. When a marketplace refuses or removes a listing because of a missing passport, this is sometimes treated as a technical problem that is "solved" by reposting the listing without addressing the underlying cause — the missing passport.

What you can document now

An overview of which marketplaces aluminium products are offered on, and what requirements each platform sets for documentation or QR linking when creating a listing.
The date and proof that the product passport (or QR code) was available before a listing went live on a marketplace.
Correspondence with the marketplace seller regarding any refusal or removal of a listing due to the passport, including the reason provided.
A link between each marketplace listing and the specific product passport that belongs to it, so that with multiple variants or suppliers no passport ends up with the wrong product — relevant for changing supplier or when purchasing from multiple suppliers at the same time.
Documentation of your own role (manufacturer, importer, distributor) per marketplace account, especially when products from different origins are sold through one account.
Agreements with the manufacturer or brand owner about who provides the passport when aluminium is resold via a marketplace as part of a private-label construction, as described on who is responsible for the passport if I supply aluminium to a brand owner.

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.