Which products from the aluminium sector fall under the ESPR?

Aluminium semi-finished products fall under the ESPR

Yes — aluminium profiles, castings and packaging aluminium fall within the scope of the ESPR. Article 1 of Regulation (EU) 2024/1781 provides that the regulation applies to physical products placed on the market or put into service, including components and intermediate products. Aluminium semi-finished products such as profiles, castings and coils or foil for packaging are typically intermediate products within the meaning of Article 2: they must be further processed — extruded, machined, coated, formed or assembled — before they reach their final application. They therefore fall under the broad definition of "product" that the ESPR employs.

Important to state directly: the fact that a product falls within the scope does not automatically mean that concrete requirements already apply. The ESPR is a framework regulation: it determines which category of products is eligible for ecodesign requirements, but the actual, product group-specific obligations — such as a digital product passport — are only laid down in a delegated act for each product group. For aluminium, that act does not yet exist.

For intermediate products, with some exceptions

The broad definition of "product" in Articles 1 and 2 encompasses virtually any physical good placed on the market in the EU, including components and intermediate products such as aluminium semi-finished products. For the aluminium sector, this means that profiles (construction, transport), castings from foundries and packaging aluminium (foil, can stock) all fall within the scope as long as they are placed on the market as physical products.

Article 1 explicitly excludes a number of categories from the scope — such as food, feed, medicines and living organisms. These exceptions do not affect the aluminium sector: aluminium semi-finished products do not fall into any of the excluded categories. There is, however, a practical distinction between the semi-finished product itself and the end product into which it is ultimately processed, for example an aluminium profile that becomes part of a window frame or a vehicle component. For some end products, such as vehicles with their own type-approval rules, parts may be subject to other regulations alongside or instead of the ESPR. Which layer of the product chain will ultimately be subject to concrete obligations — the semi-finished product, the end product, or both — depends on the delegated act established for the product group, and is not yet fixed. See Article 1 for the precise scope.

No fixed date yet, but a work plan

There is no fixed date yet for when concrete obligations for aluminium semi-finished products will take effect. The ESPR itself is already in force as a framework regulation, but it does not impose product group-specific requirements — these are set via a delegated act established by the European Commission for each product group. For aluminium, that act does not yet exist.

What is fixed: the ESPR Work Plan 2025-2030 mentions a delegated act for this sector, with an expected publication in 2027. This is a timetable, not a guaranteed date — work plans can shift. As long as the delegated act has not been published, no concrete requirements apply to aluminium semi-finished products regarding ecodesign or the digital product passport. Once the act is published, it will also set out the date from which obligations take effect, including any transition periods. Until then, the most reliable information is the text of the work plan itself and the current status at the European Commission.

What this means for the aluminium sector

For a manufacturer or importer of aluminium semi-finished products, there is currently no urgent action required, but there is something to keep an eye on now. First: determine which product group classification your own product will likely fall under — profiles, castings and packaging aluminium can each end up in a slightly different category within the work plan. Next: get your own data chain in order, regardless of the exact start date — think of alloy origin, recycling content, energy consumption in the production process and the product's destination. This type of data forms the basis of a future digital product passport in virtually every scenario, and putting it in order takes time, so starting early is worthwhile regardless of the precise legislative date. Finally: follow the announcements from the European Commission on the delegated act, because only then will the concrete requirements, thresholds and deadlines for this sector be laid down.

The basis in Article 1 and 2 ESPR

That aluminium semi-finished products fall within the scope of the ESPR follows from Article 1 of Regulation (EU) 2024/1781, which defines the scope of the regulation as physical products, including components and intermediate products, that are placed on the market or put into service. The qualification of aluminium profiles, castings and packaging material as "intermediate products" follows from the definition in Article 2, which describes an intermediate product as a product that requires further processing or treatment before it is suitable for the intended use by the end user. For the precise exclusions and the full set of definitions, the source text of these two articles is decisive.

Those who wish to prepare now can best start by inventorying their own product data — material origin, alloy composition and recycling percentage — and keeping an eye on publications from the European Commission on the ESPR work plan. Once the delegated act for this product group is published, we will update the date and the concrete requirements on this page.

What this is based on

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 itself (Regulation (EU) 2024/1781) does not name any product category by name. Article 1 establishes that the regulation creates a framework for sustainability requirements for products, and Article 2 provides the definitions that accompany it — including what is meant by a "product" and a "digital product passport". Which product groups actually come into play, and when, is determined separately for each group. For the aluminium sector, this means that the text of the ESPR sets the framework, but the question "does my product fall under it now" cannot yet be answered from this regulation itself.

Know that the framework is product-neutral.

The ESPR is written as a framework that can apply to almost any physical product, from textiles to furniture to metal semi-finished products. For a business with 10 to 100 employees, this practically means that reading the regulation itself provides little guidance on their own situation. The concrete obligations — which data, which passport, from which moment — come only with a separate, product-specific regulation. More on this can be found under what a delegated act is and why it determines what must happen.

Understand that "product" is defined broadly.

Article 2 of the ESPR defines a product broadly: it concerns goods that are placed on the market or put into use. For aluminium semi-finished products, this means that rolled sheet, extruded profiles and cast components can in principle fall within the scope of the term "product". That is a different question from whether an obligation already applies — in practice these two often blur together. Anyone wondering whether that specifically applies to their own profiles or castings will find the details under profiles and extrusion..

Distinguishing between semi-finished product and end product

An aluminium sheet that a façade cladding manufacturer purchases is a semi-finished product for that manufacturer, but it can at the same time be the end product of the aluminium supplier. The ESPR does not regulate this distinction with a simple line; it depends on what the product-specific regulation for that category establishes. In practical terms, for a business that further processes or resells aluminium, the question "who compiles the passport" can only be answered once it is known which link in the chain is designated as the provider of "the product". This topic is developed further under semi-finished product versus end product.

Check whether your sector is already mentioned in the work plan.

The European Commission works with a work plan that indicates, for each product group, when a delegated act is expected. For the aluminium sector, this has not yet been published; the expectation around 2027-2029 is a planning date, not an established obligation. A business that wants to know now whether profiles, castings or packaging aluminium will be specifically named will find the current status under when the product passport becomes mandatory for aluminium and under what the ESPR changes for the aluminium sector..

Where things go wrong in practice

A first situation that often occurs: a business reads the ESPR text itself, sees that "aluminium" is nowhere to be found, and concludes that therefore there is nothing to do. The regulation does not work that way — the product-specific implementation comes separately, and the absence of a name in the basic regulation says nothing about whether aluminium products will or will not fall under it.

A second situation: a foundry that exclusively manufactures components to order for the repair of existing machinery assumes without further checking that loose components are always excluded. Whether that is the case depends on how the future regulation treats spare parts; that is a question that is answered separately, not something that can be derived from Article 1 or 2 of the ESPR. See on this subject loose aluminium spare parts.

A third situation: a dealer in recycled aluminium assumes that secondary aluminium will remain out of view because the ESPR would "mainly be about new raw materials". The regulation does not make that distinction in that way; whether primary or secondary material makes a difference is a question that is filled in per product group. More on this under primary or secondary aluminium..

A fourth situation: a small family business with twelve employees assumes that the rules only apply to large industrial producers and does not even raise the question. Company size is not the primary factor determining whether a digital product passport will apply; this is determined by the product category. See digital product passport and small businesses.

A fifth, common situation: an aluminium packaging producer of foil containers assumes that packaging material automatically falls under the same rules as construction profiles, simply because it is also aluminium. Within EU policy, packaging often has its own regulatory pathway alongside the ESPR. See aluminium packaging.

What you can document now

A brief note on which product group(s) the company actually manufactures or trades (sheet, profile, casting, packaging, semi-finished product or end product), as a basis for later assessing compliance with a delegated act once it is published.
An overview of the company's own position in the supply chain: who is a supplier, who brings the final product to market. This is relevant because the obligation is assigned to a specific link in the chain, not automatically to the manufacturer of the raw material.
A reference or link to the Commission's work plan, so that it can be checked periodically whether the company's own product group has been added or announced.
Documentation of which aluminium alloys and applications are produced (construction, transport, packaging, castings), so that when a delegated act is published, it can be quickly determined whether the company's own range falls within it.
A note on whether the company's own product is sold as a semi-finished product to a third party that processes it further, relevant to the later question of who compiles the passport. More background on this can be found under what a digital product passport for aluminium contains and under which data are included in the aluminium passport.

Anyone who, after this inventory, wants to know whether their own situation already has concrete contact with the ESPR, will find a more direct path at whether the digital product passport applies to your own aluminium.

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.