What do I do with aluminium stock that is already in place when the rules come into effect?

What you must concretely do

What is expected of you

Stock that is already on hand when requirements for a product group take effect is a question that the ESPR does not answer with a single simple rule. The regulation itself (Regulation (EU) 2024/1781, Article 1) describes the framework and scope of application, but the concrete requirements per product group — and thus also whether and how existing stock is handled — only come with the delegated act that is being prepared for aluminium. What this precisely entails is described on the page about what a delegated act is and why it determines what you must do. Until that act is in place, there is no established transition provision for aluminium to refer to.

Know when which date applies

Article 18 of the ESPR concerns the prioritisation and planning of product groups: the European Commission determines the order and timeframe in which product groups come into scope. For a company with 10 to 100 employees, this means there is not one entry date for "aluminium", but a date that is established per delegated act. Planning stock management based on a date that has not yet been published is therefore premature. In practical terms, this means that following the work plan and announcements regarding the delegated act is more important than pre-setting an internal cut-off date for the supply of undocumented stock.

Assess whether existing stock falls within the new requirements

Whether aluminium products already in the warehouse fall within the scope of application as described in Article 1 of the ESPR depends on the precise product group classification that is still to come. A company that currently holds stock of profiles, castings or packaging aluminium can categorise that stock by type and application, so that once the delegated act is in place, it is quick to determine which part of the stock may fall within the new requirements. This is not a legal obligation now, but it is a practical preparation that saves a lot of investigation work later.

Document what data is already known

For stock that has already been produced or purchased, data is often already available: composition, origin, supplier, batch number. This data is the basis from which a product passport will later be compiled. Organising them now — by batch, by supplier, by product code — is not an obligation, but it does align with the steps described on the page about how you tackle the product passport for aluminium step by step. The better this data is already in order, the less investigation work there will be when a passport actually needs to be created.

Where things go wrong in practice

Stock is treated as one large batch. A company with different production lines or purchasing lines puts all aluminium stock in one heap in the administration, without distinction according to alloy, processing form or destination. Once it becomes clear which product group receives requirements first, everything must be split up afterwards.

Waiting for everything until the entry date is known. Some companies defer all preparation "until it is certain". The consequence is that when the delegated act is published, there is no time left to collect data on stock that has been in the warehouse for months or years.

Supplier data can no longer be traced. Stock that remains in storage for a long time sometimes becomes detached from the original purchase documentation. If a supplier no longer exists or a contact person has left, gathering composition data for older stock becomes a problem anyway.

Confusion between "still sell" and "still destroy". Companies that want to dispose of stock before new requirements take effect sometimes wonder whether destroying is faster or easier than selling under the new rules. This is a different question from stock management, and is addressed separately on the page about whether unsold aluminium stock may still be destroyed.

Internal communication is lacking. The warehouse staff, the procurement officer and the sales department each have a different picture of what should happen with existing inventory, because no one has had the conversation about what is already known and what still needs to be recorded. How that conversation is conducted internally is discussed on the page about how you explain to colleagues what changes with the digital product passport.

What you can document now

• An overview per inventory batch of alloy, processing form and original supplier, so that traceability is not dependent on one person or one system.
• Procurement documentation and certificates that are already available, bundled per batch or lot number instead of scattered across different departments.
• A record of the production date or purchase date of each inventory batch, so that when an entry date becomes known, it is quickly clear which inventory was created before and which after.
• An internal contact point or process owner for inventory data, so that questions about this do not remain unresolved between departments.
• A test environment in which you can already practice assembling a passport for part of the inventory, as described on the page about whether you can already test a digital product passport before it becomes mandatory. That makes it clear which data about existing inventory is already sufficient and which is still missing.
• A list of product types and codes that are eligible for joint registration, in case it later turns out that multiple products can be registered together for a digital product passport, which saves time with larger inventory positions of the same type of product.