What can I already do while the rules are not yet final?

What you must concretely do

The delegated act for aluminium does not yet exist, and the date on which the digital product passport becomes mandatory is therefore not yet fixed. This does not mean there is nothing to do. The ESPR itself (Regulation (EU) 2024/1781) is already in place, and the way the European Commission sets priorities for product groups — including aluminium — is described in Article 18. Whoever puts their house in order now will be better positioned once the obligation becomes concrete. This article describes what that involves, without pretending the rules already apply.

What is expected of you

Getting clarity on your own product information

A product passport consists of data that a company already largely has in-house: composition of the aluminium alloy, origin, processing steps, and if applicable recycling percentage. At many companies with 10 to 100 employees, that information is scattered across purchasing files, quality certificates and emails with suppliers. Mapping now where that data is located and whether it is complete is not a legal obligation, but it is the most practical preparation there is.

Knowing who in the chain must supply what

Article 38 of the ESPR addresses the obligations of actors in the supply chain: manufacturers, importers and other parties who must supply or pass on product information. For a processor of aluminium profiles, this means that the company's own role in that chain can already be determined now — does the company itself supply data to a passport, or is it dependent on what a foundry or importer supplies. Whoever has that clear now avoids disputes later over who must supply which part of the passport.

Monitoring which product group receives priority

Article 18 describes how the Commission draws up work programmes and prioritises product groups for delegated acts. Aluminium semi-fabricated products are on the agenda, but the order and pace are up to the Commission. A company wishing to follow this can best do so by periodically checking whether there is news about the delegated act, rather than guessing at a date. More on how such a delegated act works exactly and why it determines what a company is expected to do is described on what is a delegated act and why does it determine what I must do.

Testing without obligation

Nothing prevents a company from already trying what a product passport looks like in practice, with the data already available. That is not a legal step, but a way to discover where your own administration falls short before that has to happen under time pressure. How that works in practice is explained on can I test a product passport now before it becomes mandatory.

Where things go wrong in practice

Waiting until the date is fixed. Some companies postpone all preparation until the delegated act is published. The consequence is that they then have to do everything at once: gather data, question suppliers, set up systems — all within the time remaining after publication.

Unclear about who in the chain supplies what. At companies that buy, process and resell aluminium, it is often not established who manages which part of the product information. If there is no conversation about this now with suppliers and customers, that discussion will arise later under time pressure.

Staff that does not know what is changing. Sales, purchasing and quality often hear separately about "something with a passport", without clarity on what that concretely means for their work. That leads to noise and missed signals. How to have that conversation internally is described on how do I explain to my colleagues what changes with the product passport.

Assumptions about costs. Sometimes estimates are already being made with amounts that have no basis, or not budgeted at all because "it is not yet mandatory". A realistic picture of what a passport may cost is on what does a digital product passport for aluminium cost.

Unclear about which aluminium product is involved. Not every aluminium product will automatically fall under the same rules in future. Companies that want to know now whether their specific semi-fabricated product falls within the expected scope will find a starting point on does the digital product passport apply to my aluminium.

What you can document now

Even without a definitive obligation, it is possible to put a number of things in order right now. That saves time once the delegated act is in place:

• An overview of product groups and volumes. Which aluminium semi-finished products are produced or traded, and in what quantities. Useful if it later turns out whether the registering multiple products for a product passport at once is applicable.

• A list of data already available per product. Alloy composition, certificates of origin, process documentation, recycling data — what exists, where it is stored, and who manages it.

• Agreements with suppliers on data exchange. Particularly relevant for companies acting as intermediaries in the chain and depending on what a manufacturer or importer has supplied earlier in the chain, as intended in Article 38 of the ESPR.

• An internal contact point or small project team. One person or a small team that follows developments and informs the rest of the organisation, preventing knowledge from becoming fragmented.

• A note on existing stock. For stock that is already in place when the rules take effect, different transition arrangements may apply. What is currently known about this is set out on what do I do with aluminium inventory that is already there when the rules take effect.

• A step-by-step plan for your own organisation. An overview of the steps that must be taken at a given time, from data collection to registration, can be found on how do I implement the product passport for aluminium step by step.

None of these steps is mandatory as long as the delegated act has not been published. But those who take them now will not have to start from scratch later.