When does the product passport become mandatory for aluminium?

What you must concretely do

What is expected of you

The ESPR (Regulation (EU) 2024/1781) is a framework regulation. This means that the regulation itself does not contain an obligation to implement a product passport for aluminium from a fixed date onwards. The regulation describes the system, the powers and the procedure; the actual obligation per product group comes through a separate decision. For those wondering what this entails precisely, there is an explanation about what a delegated act is and why it determines what must happen.

The European Commission draws up a work plan

Article 18 of the ESPR requires the European Commission to draw up a work plan stating which product groups are to be covered and when. For a company, this means above all that there will come a moment when aluminium products — or some of them — appear by name in that work plan. This is the first serious signal that a delegated act is in preparation. The work plan itself is not an obligation, but rather an announcement of what is to come.

The Commission adopts a delegated act for each product group

Articles 4 and 8 of the ESPR provide that the Commission adopts a delegated act separately for each product group. That act determines, among other things, which products are precisely covered by the obligation, which data must be in the passport, and from which date the obligation takes effect. For aluminium semi-finished products, this act does not yet exist. As long as it does not exist, there is no concrete obligation and no concrete date either. This is a different situation from products for which the act has already been published — that difference is relevant for those planning ahead.

A company with 10 to 100 employees follows the announcements, not speculation

In practical terms, this means for a medium-sized company that no action is required at this time on the basis of a fixed date, simply because that date does not yet exist. What is practical: keep track of when the delegated act for aluminium is published, and do not rely on an estimate that has become accepted as fact internally. Around alupas.eu, 2029 is mentioned as an expectation, based on the ESPR work plan 2025-2030 which mentions a delegated act for 2027 — but this is an expectation, not an established date. As soon as the act is published, the final date will appear here.

Where things go wrong in practice

An expected date is treated as a firm deadline. Internal planning, quotations to customers or investment decisions are based on "2027" or "2029", while that is an estimate and not a legal date. If the delegated act comes later or is implemented differently, the entire plan will be off.

People wait until the act is published before anything is organised. The data that will have to be included in a passport — origin, composition, recycling percentage — are often already recorded here and there, but not centrally. Waiting until the obligation is in place means that the collection of historical data will then still have to happen, with all the gaps that will exist by that time.

No distinction is made between the work plan and the delegated act. The appearance of aluminium in the work plan is taken for an obligation, whereas the work plan is merely a schedule. This leads to action being started too early or too late, depending on how the message is interpreted.

The question "does this apply to our type of aluminium" is not asked before the date is known. Companies wait with answering the question whether the product passport applies to their aluminium until there is a date, whereas that question is independent of timing and can be answered now on the basis of what is known about product groups.

Semi-finished products are disregarded because "only the end product counts anyway". For those who supply profiles, castings or packaging aluminium that will later be processed into an end product, it is not self-evident that the obligation only lies with the end product. That question — whether a passport is already required if the aluminium is still a semi-finished product — is posed too late, whereas the answer affects who in the supply chain must provide the data.

What you can document now

• An internal note with source reference for the expected date. Not "2029" without explanation, but with the statement that this is an estimate based on the ESPR Work Plan 2025-2030 and that the delegated act for aluminium has not yet been published.
• A fixed control moment (for example every quarter) to check whether there is news about the delegated act for your own product group, instead of leaving this to chance.
• An overview of which products from your own assortment are presumed to fall under the obligation, based on the classification already known from the regulation. See also the explanation on which products from the aluminium sector fall under the ESPR.
• A list of data that are already available on origin, composition and processing, so that these do not have to be traced back later. A starting point for this is in the overview of what data will be included in the aluminium passport.
• A note on who in the supply chain is responsible for providing data — manufacturer, importer or processor — so that this agreement is not made only when the deadline is already approaching.