What does the ESPR change for the aluminium sector?

What you must concretely do

What is expected of you

The ESPR (Regulation (EU) 2024/1781) is a framework regulation. This means that the regulation itself sets out what can in principle fall within its scope — almost all physical products, with a number of exceptions — but that the concrete requirements per product group will be specified later. Article 1 of the ESPR describes the subject matter and scope: it concerns rules for ecodesign that must improve the environmental performance of products, with the digital product passport as one of the instruments within this framework. For the aluminium sector, this does not immediately mean changes on the shop floor, but the regulation does determine the playing field within which later, more specific rules will apply.

Knowing that the framework is in place

For a company with 10 to 100 employees, this means above all: taking note of the fact that the ESPR exists and that aluminium products can in principle fall within its scope. There is no direct obligation to register or submit anything now. What is practical: to check which own products may be eligible, for example profiles, castings or packaging material. On which products from the aluminium sector fall under the ESPR is an overview of how that delimitation works in practice.

Following the delegated act for the own product group

The concrete requirements — which data, which format, which thresholds — do not come from the ESPR itself, but from a delegated act that is established for each product group. For aluminium semi-finished products, that act does not yet exist. For a company, this mainly means keeping track: which delegated act concerns aluminium, and when will it be published. On what is a delegated act and why does it determine what I must do it is explained why this document will ultimately be more important for daily practice than the ESPR text itself.

Assessing whether the own company falls within the scope

Not every company that works with aluminium automatically falls within the same rules. There is a difference between a manufacturer who processes primary aluminium and a company that works with secondary (recycled) aluminium, and there is a difference between a semi-finished product and a finished product. These distinctions partly determine whether, and when, a product passport is required. See for this makes the difference whether my aluminium is primary or secondary and a product passport must already be in place if my aluminium is still a semi-finished product.

Checking whether the own company size plays a role

Some arrangements within the ESPR structure provide room for smaller companies, for example in the form of transition periods or lighter obligations. Whether, and in what form, this will apply to a specific aluminium product depends on the delegated act yet to be published. A company with 10 to 100 employees is well advised not to consider this point as "settled" or "not applicable" beforehand. More on this can be found on does the product passport also apply to small companies.

Where things go wrong in practice

In practice, a few recurring misunderstandings about the ESPR arise.

A first is that companies confuse the ESPR with a directly applicable obligation, whereas the regulation itself mainly sketches the framework. Anyone waiting for "the law that makes the product passport mandatory" reads article 1 and thinks that is the finish line, whereas the actual requirements still have to be established in a separate document.

A second is the assumption that all aluminium products are treated with the same brush. A profile manufacturer and a packaging producer face different questions, and the classification of the own product — semi-finished product, finished product, primary or secondary material — partly determines how the later rules will work out.

A third situation is that companies think that "not yet mandatory" is the same as "nothing to do yet". Whereas compiling the underlying data — source of the material, composition, processing steps — often takes more time than the technical part of the passport itself.

A fourth source of confusion is the distinction between the role of the manufacturer and that of a spare parts supplier. For loose parts, the question differs from that of a complete new product, and in practice this distinction is frequently overlooked.

A fifth, common situation is that companies cite a date they have read somewhere — 2027, 2029 — as an established fact, while at this stage that date is an expectation, based on the ESPR work plan, and may change once the delegated act itself is published.

What you can document now

• An overview of which of your own product groups may potentially fall under the ESPR, with a brief explanation of why (semi-finished product/end product, primary/secondary material).
• A note on company size and its possible relevance, so that this point is not forgotten once the delegated act appears.
• A list of products that may be supplied as spare parts, separate from the regular product line — see a product passport must be included with loose aluminium spare parts for the background on this.
• A file containing the origin and composition of used material, so that the basic data are already available when a delegated act sets concrete requirements. Which data these are expected to be is explained on which data come in the digital product passport for aluminium.
• A standing appointment, for example internally or with an adviser, to monitor the publication of the delegated act, so that any change does not pass unnoticed.
• A brief internal explanation of what a digital product passport entails, so that everyone within the company has the same basis — usable as an introduction is what is a digital product passport for aluminium.