What is a digital product passport for aluminium?

What you must concretely do

What is expected of you

A digital product passport is, according to Article 9 of the ESPR (Regulation (EU) 2024/1781), a collection of product data that is electronically accessible via a data carrier. For aluminium, this concerns data on the origin, composition, and properties of the material, linked to a specific batch or a specific product. The passport itself is not a separate document that a company designs itself: the structure, the arrangement of data and the technical format are fixed in rules that are developed for each product group. What this concretely means for aluminium is described on the page about what a delegated act is and why it determines what must happen.

Providing data that is correct and current

The basis of the passport is the information that a manufacturer or importer provides. For a company with 10 to 100 employees, this mainly means that data that already exists somewhere – in quality certificates, material specifications, purchase documents – must be structured and available in a fixed location. This is often less a technical problem than an organisational one: the data exists, but is scattered across different departments or systems. Which data precisely ends up in the aluminium passport can be read on the page about which data will be included in the aluminium product passport.

Ensuring that the passport can be linked to the correct product

Article 9 of the ESPR describes that the passport must be linked to a unique product or product group. For aluminium semi-finished products, this means that there must be an unambiguous relationship between a batch of material and the associated passport data. For profiles, castings or coils that can vary per batch or per composition, this is a practical task: traceability must be correct at the level at which the passport is issued. Whether this specifically applies to profiles and extrusion is worked out on the page about the product passport for aluminium profiles.

Keep the data carrier (QR code) accessible

Article 10 of the ESPR (Regulation (EU) 2024/1781) describes requirements for the data carrier through which the passport is accessed, in practice a QR code or similar code on or with the product. For a company, this means that the code must be applied physically in a way that aligns with how the product is traded, and that the underlying data remains accessible during the specified period. The latter is an obligation that does not end at the point of sale: the data must also be accessible years later.

Know whether your own product falls under the obligation

Not every aluminium product automatically receives a passport. The ESPR works with delegated acts per product group, and these are established in phases. A company that wants to know whether its own assortment falls under the rules will find a detailed answer on the page whether the digital product passport applies to your aluminium. The question whether this only applies to large producers, or also to smaller companies, is also addressed on the page about whether the product passport also applies to small companies.

Where things go wrong in practice

A few situations come up repeatedly with companies preparing for the product passport.

Data exists, but not in one place. A foundry has material certificates, melt analyses and purchasing data, but these are held by different suppliers, in different formats, and sometimes only on paper. The passport calls for a structured whole, not loose documents that must be collected afterwards.

Uncertainty about who must provide the data. For aluminium that goes through multiple links in the supply chain – producer, importer, processor – it is not always clear who is responsible for which part of the information. This is a particular issue for companies that purchase semi-finished products and process them further; the question whether a passport must already be present when the material is still a semi-finished product is addressed on the page about semi-finished product versus end product.

Confusion between primary and secondary aluminium. Companies working with recycled material sometimes assume that the origin of the aluminium makes no difference to the passport. Whether that is correct depends on how the delegated act fills this in; the page about whether it makes a difference whether aluminium is primary or secondary goes further into this.

Spare parts are forgotten. A company that supplies loose aluminium parts for repair sometimes assumes that only complete products need a passport. Whether this also applies to spare parts is described on the page about product passports for loose aluminium spare parts.

The QR code is seen as the final touch, not as part of the process. Some companies think that affixing a code is the last step, while the underlying data must remain accessible for ten years. This requires a hosting agreement and a maintenance process, not just a sticker on a product.

What you can document now

• An overview of which product groups within your own range may fall under the ESPR, including a reference to the applicable delegated act as soon as it is known.
• An internal list of where material data (certificates, melt analyses, certificates of origin) are stored and who is responsible for them.
• Agreements with suppliers about which data they provide and in which format, especially for aluminium that is traded through multiple links.
• A documented link between product batches and the corresponding passport data, so that traceability at batch level is demonstrable.
• A process for keeping data up to date during the period in which the passport must remain accessible.
• An overview of which products may be exempt, for example spare parts or specific packaging applications; see also the page about packaging aluminium and the product passport.