What happens to the digital product passport if my company closes?
The passport does not disappear automatically with the company
No, the digital product passport does not automatically cease to exist at the moment the company that provided the data stops existing. A product passport belongs to the product, not to the website or the legal entity that once created it. Once an aluminium semi-finished product has been placed on the market with a passport, that passport remains in principle accessible to anyone who needs it — a processor, a recycler, a supervisory authority — even if the manufacturer or importer has since ceased operations, gone bankrupt or been taken over. The practical aspect of this depends on who hosts the data: at alupas.eu, this is guaranteed for a period of ten years, regardless of whether the supplying company still exists.
For existing products, not for new production
This distinction is important. The obligation to continue updating a passport belongs to a company that actively places products on the market; that obligation logically ceases once there is no longer any production or import taking place. That is different from the question of whether an already published passport remains accessible for products that have already been sold or processed — that accessibility is separate from the question of whether the original supplier is still active. This section does not address what happens in the event of a takeover or merger: in that case, responsibility for existing passports generally transfers to the legal successor, and it is up to that successor to register itself as the new responsible party. This section also does not address termination of the hosting contract itself — that is an arrangement between the company and the party hosting the passport, not something regulated by the ESPR itself.
No fixed date yet, so no obligation now
There is currently no legal obligation for aluminium semi-finished products to have a digital product passport. The delegated act that will make this concrete for this product group is expected in 2027 according to the European Commission's work plan for 2025-2030; an exact entry-into-force date for aluminium has not yet been set. As long as that act is not in place, the question "what happens when we stop" is therefore not yet a legal obligation, but it is already a practical question for companies preparing themselves. Once the obligation takes effect, the requirements of the ESPR regarding availability of the passport apply from that point forward to products placed on the market.
What to do if the company stops
For a company considering stopping or that has been taken over, the sequence is roughly as follows. First, it is important to determine whether there is a legal successor — an acquiring party, a continuing business — that can take on the role of responsible party for existing passports; that party can then register with the hosting party as a new contact person. If there is no successor, the passport nonetheless remains accessible via the hosting party, without anyone actively updating the data. It is also advisable to keep your own records of delivered products and associated passports, even after business cessation, in case a customer, processor or supervisory authority has questions later. Finally, it is recommended to check whether the product and associated data have also been included in the central EU register of product passports, so that findability does not depend solely on one hosting party.
Where this is stated: Articles 10 and 13 of the ESPR
This explanation follows from two parts of the ESPR (Regulation (EU) 2024/1781). Article 10 describes the requirements for a digital product passport, including the accessibility of information to parties entitled to it — a requirement linked to the product, not to the continued existence of a specific company. Article 13 provides for a register of digital product passports at EU level, in which passports are centrally recorded. That register ensures that the registration of a passport is not entirely dependent on one website or hosting party.
If you are already working with alupas.eu or considering doing so, it is best to address the question of business cessation early on in the agreements on hosting and transfer, so that in the event of a shutdown it is clear who manages the data and how long it remains accessible.
What this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 10 (requirements for the digital product passport)
- Regulation (EU) 2024/1781 (ESPR), Article 13 (register of digital product passports)
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
What is expected of you
The ESPR requires that the digital product passport of a product remains available even if something changes in the company that had the passport prepared. Article 10 of the ESPR (Regulation (EU) 2024/1781) sets requirements for the availability of the passport; nowhere does it state that this obligation lapses once a company ceases to exist. For a manufacturer or importer of aluminium semi-finished products, this means that the end of the undertaking does not automatically mean the end of the passport.
The passport remains in existence, even without the original manufacturer
A product passport is linked to a product already placed on the market, not to the continued existence of the party that had the passport drawn up. For a profiles manufacturer or foundry of 10 to 100 employees, this means in practice that the aluminium products already sold and processed retain their passport — regardless of what happens to the company itself. How long that passport must remain available is described on the page about how long a product passport must remain available.
The registration in the European register does not automatically change along
Article 13 of the ESPR describes the register of digital product passports, in which data on passports is entered. If a company ceases operations, the registration does not automatically disappear from that register. For a packaging aluminium producer, this means that the question of who is responsible for the accuracy of the register data remains relevant — even when there is no operational company behind it anymore. What exactly must be included in that register is described on the page about the register of digital product passports.
The hosting party of the passport continues to play a role
Because alupas.eu hosted the passport and supplies the QR data carrier, that hosting function persists independently of the company that provided the data. For a company that ceases operations, this means in practice that the technical availability of the passport — the server, the link behind the QR code, the accessibility of the data — is a separate matter from the question of whether the company itself still exists. These two matters do not automatically run in parallel.
Takeover, merger or continuation affects responsibility for the data
If a company ceases operations through takeover, merger or continuation, there remains a party responsible for the accuracy of the data in the passport. For a foundry that is taken over, this means that the question of who is the contact point after the takeover for any changes to or questions about the passport is something that requires attention. In case of a normal continuation through a new legal entity, the question may arise whether data must be adjusted — see also the page about amending data after publication.
Where things go wrong in practice
A number of situations regularly occur in companies that cease operations, merge or are taken over.
Insolvency without transfer of contact details. A profiles manufacturer goes bankrupt and the receiver focuses on the settlement of debts and assets. Nobody thinks about the question of who will be reachable for questions about the product passport of products that will remain in buildings or vehicles for years to come.
Takeover without the passport being transferred as part of the handover. In a business takeover, attention is focused on customers, inventory and personnel. The responsibility for existing product passports is not explicitly mentioned in the takeover agreement, leaving it unclear who after the takeover is responsible for that responsibility.
Discontinuation of hosting without an alternative. A company that hosted itself rather than via a platform such as alupas.eu takes its server offline when it ceases operations. The QR code on the product then points to a non-existent page — something that is related to the question what happens if the QR code becomes unreadable, although here it is not a matter of damage but of a deliberate choice that equally results in a dead link.
Restart under a new name without arranging the link to existing products. A foundry restarts under a new name after a bankruptcy. The new business has no legal connection to the old products and therefore does not feel responsible for the product passports that were created under the old name — while products with those passports remain on the market.
No recording of who manages the source data. If the company only kept the source data of the passport locally — in an ERP system that is shut down when operations cease — there is no one left who can consult the underlying data when questions arise about the composition or origin of the aluminium. See also the page on linking the passport to your own ERP or inventory system, where this dependency is explained.
What you can document now
A number of agreements and documents help to make the transition predictable in the event of closure, takeover or merger, even though the law itself does not determine exactly how that process should proceed:
- An overview of which products have a product passport, including the unique identification code per product or batch — see the explanation on a unique identification code per product and on register per batch or per unit.
- An established agreement with the hosting provider (such as alupas.eu) on what happens to the hosting when the business ceases, including a contact point for the remaining duration.
- A provision in the takeover agreement or asset transfer that explicitly states who is responsible after takeover for existing product passports and for maintaining the register data.
- An archive of the source data underlying the passport, separate from the internal ERP system, so that this data is not lost when the system is shut down.
- A list of products with multiple passports where applicable, with an explanation of their interrelationship — relevant for more complex products, as described on the page on multiple product passports for one product.
- A note on the language versions that have been published, so that a successor knows what information is available — see also multiple language versions display via one QR code.
These arrangements do not prevent a company from ceasing operations, but they ensure that the product passport of products already on the market does not simply end up in an information vacuum.
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.