What does a product passport for aluminium cost?

What you must concretely do

The ESPR (Regulation (EU) 2024/1781) stipulates in Article 9 what a digital product passport must be able to do: record data, link it to a product via a carrier such as a QR code, and keep that data accessible for a specified period. The regulation says nothing about what this may cost. There is no amount, no tariff and no cost ceiling in the text — nor would that make sense, since the cost of a passport depends on how many products are involved, how much data per product is needed, and which party sets it up and hosts it for a company. Anyone looking for a specific amount in the legislative text itself will not find it. What can be described, however, is: which items come up in practice once a company has a passport made, and where the costs usually come from.

What is expected of you

Providing data that is correct and complete

A product passport is only as good as the data it contains. Article 9 of the ESPR requires that the information in the passport corresponds to the product to which it is linked. For a company with 10 to 100 employees, this means: someone must collect and provide the technical specifications, origin, composition and any certificates. This is not a cost item from an external party, but it is internal time — often from a quality employee or technical manager who is already working with this data.

Applying a data carrier to the product

The passport must be linked to the physical product or packaging via a carrier, usually a QR code. For aluminium semi-finished products, this means a modification to the production process or packaging line: a label, an engraving, or a sticker with the code. The costs of this are not in the legislative text, but in practice lie in the adaptation of existing production and packaging processes.

Having the passport hosted for the required period

After publication, the data in the passport must remain accessible for a certain time. This requires hosting: a server or platform that allows the QR code to point to current, accurate data for years to come. For a company that does not have its own IT infrastructure for this purpose, this is usually the reason to engage a platform instead of setting it up itself.

Keep data up to date

A passport is not a snapshot that you make once and then forget about. If a product changes — a different alloy, a different raw material supplier — that must, where relevant, be reflected in the passport. This is an ongoing task, not a one-time cost item.

Where things go wrong in practice

A first situation: a company requests a quotation based on "one product passport" and is surprised by the price per product once it becomes clear that each alloy variant or each size profile must be registered separately. If you market multiple variants of the same basic product, it is wise to check beforehand how can I register multiple products at once for a product passportthis difference in approach affects the final costs significantly.

A second situation: internal time is not factored in. A company thinks "the platform will handle it" and underestimates how much time it takes to collect and provide the right technical data, certificates and origin information yourself. That time is a real cost item, even if there is no invoice for it.

A third situation: a company waits until the delegated act is in place before investigating anything, and then discovers that internal processes — such as applying a QR code to the packaging line — require more preparation time than expected. Running a test run in advance saves delays; it is worth considering checking can I test a product passport now before it becomes mandatory.

A fourth situation: costs are only allocated to one department, usually procurement or quality, while production, packaging and IT are also affected. Without the colleagues on the floor understanding why a code needs to be on the product, errors and delays occur that cost money. That is why it is useful to determine early how do I explain to my colleagues what changes with the product passport.

A fifth situation: a company assumes that costs only become relevant once the obligation officially takes effect, and does not realize that inventory already in the warehouse at the moment the rules take effect also requires attention. What is then practically expected with existing inventory is described at what do I do with aluminium inventory that is already there when the rules take effect.

What you can document now

• An overview of all product variants (alloy, dimensions, packaging unit) that may need to be registered separately, so that a quote from a platform is comparable with the actual scope.
• A list of the data that are already available per product (material certificates, certificates of origin, technical datasheets) and the data that still need to be collected.
• Agreements on who within the company is responsible for keeping the data up to date after publication of the product passport, including how changes to the product are communicated.
• An assessment of the adjustment needed in the production or packaging process to apply the data carrier, including who carries it out and how frequently.
• The results of a test project, if one has already been carried out, so that it is clear which steps will then need to be repeated for the rest of the assortment.
• An overview of which products fall within the scope; those who have not yet clarified this can first check does the digital product passport apply to my aluminium before cost estimates are drawn up for products that may fall outside the obligation.

What the actual price per product passport will be cannot yet be fixed in an amount — that follows from the market and from the delegated act that determines the precise data requirements per product group. What can be fixed now is the basis: which products, which data, and which internal roles. Those who have this in order can, as soon as the obligation gets a fixed date, quickly make a realistic price comparison instead of starting from scratch.