what happens if the QR code on my aluminium becomes illegible

A damaged QR code does not mean the passport is gone

The QR code on an aluminium semi-finished product is a reference to the product passport, not the passport itself. The passport is stored on a server, linked to a unique identification code of the product, and remains there even if the carrier on the product scratches, wears or becomes unreadable through processing. The problem with a damaged code is therefore not that the data has disappeared, but that someone can no longer access it at that moment with a simple scan. This is particularly inconvenient for those further down the chain — a processor, a recycler, an inspector — who may need the data at precisely that moment.

This is about the carrier, not the data

The distinction that matters here: the carrier (the QR code, engraved, etched or applied as a label) is different from the digital product passport behind it. Article 11 of the ESPR (Regulation (EU) 2024/1781) sets requirements for the technical functioning of the passport and the data carrier, and assumes a carrier that can withstand what the product normally undergoes in practice. This means that the starting point is a QR code that is created and applied with a view to the durability of the carrier itself. What this article does not regulate is a guarantee that a code can never become unreadable — extreme processing, corrosion, coating or mechanical damage can still render a code unusable. For that situation, there is no separate "emergency procedure" in the text; however, the underlying link between product and passport remains intact via the identification number, as is also addressed in how you give each product a unique identification code. That number, and not the QR image, is the actual anchor point.

No fixed date yet, but a fixed direction

When these obligations for aluminium products come into force precisely is not yet fixed. The delegated act that must make this concrete for aluminium semi-finished products is expected around 2027 according to the ESPR work plan 2025-2030; once it is published, the date will appear here. Until then, nothing changes in practice: there is currently no legal obligation to bear a QR code on aluminium products. What is already fixed is the framework within which this must then happen — Article 10 and Article 11 of the ESPR describe what the passport and the carrier must comply with once the obligation comes into force for a product category.

What to do if a code becomes unreadable later

For those already thinking about how to set up this process, the order is roughly as follows. First: ensure that the passport is not only findable via the QR image, but via an identification code that can also be traced without the code — on accompanying papers, on a delivery note, or in the register of digital product passports in which the passport is included according to Article 13 of the ESPR. That register serves as a finding aid that does not depend on the physical condition of the product. Next: consider where in the process the code runs the greatest risk of being damaged (transport, coating, heat treatment) and choose the method of application — engraved, etched, as a durable label — that best withstands it; this is a matter that is addressed in more detail in how the QR code gets onto the product. After that: if a code does get damaged at a customer or processor, the practical route is to look up the identification code of the product (via accompanying documents or the register) and use it to access the passport, without having to scan the code itself. Finally, it is wise not to leave this process standing alone: a link with the company system, as described in linking the passport to an ERP or inventory system, makes it easier to find a product passport without the physical code having to be readable.

Traced back to the articles on carrier, passport and register

The basis for this answer lies in three articles of the ESPR (Regulation (EU) 2024/1781). Article 10 describes the requirements that a digital product passport must meet, including the link to a unique identification code — independent of the physical carrier. Article 11 addresses specifically the technical design and operation of the passport and the data carrier, and is where requirements for the durability and readability of the QR code itself will be specified once a delegated act for aluminium has been established. Article 13 governs the register of digital product passports, which serves as a central reference point separate from what happens with the physical product itself. Article 16 and Article 17, on labels and counterfeit labels, are relevant to the question of how a code must be visually recognizable and non-counterfeitable, but say nothing about what happens if an authentic code is damaged — that remains within the scope of Article 10 and 11.

Companies that prepare an aluminium product with a QR code now would be well advised to design the identification code and its storage (register, ERP, accompanying documents) independently of the physical carrier on the product itself — once the date and the delegated act are in place, that is the basis that is already established.