What does an enforcement authority ask for during an inspection on aluminium?
Documentation demonstrating that the product is compliant
A competent authority essentially requests evidence that a product meets applicable requirements: technical documentation, a declaration of conformity, data on who placed the product on the market, and where applicable the digital product passport. Regulation (EU) 2019/1020 empowers market surveillance authorities to request this information from manufacturers, importers, authorised representatives and distributors, and to verify its accuracy and completeness. For aluminium semi-finished products that will soon fall under the ecodesign regulation (ESPR, Regulation (EU) 2024/1781), there is the additional question of whether the product passport is present, up to date and accessible via the QR code or equivalent data carrier. As long as the passport for aluminium is not yet mandatory, an inspection focuses on the documentation that is already mandatory under the applicable legislation at that time.
For economic operators, not for every aluminium product
This question applies to economic operators responsible for a product falling under EU product legislation: the manufacturer or importer placing the product on the market in the EU, and by extension distributors reselling it. It does not automatically apply to every piece of aluminium that a company processes or handles — a semi-finished product used only internally or that does not yet fall under a specific delegated act of the ESPR has no passport requirement at present. The distinction between 'placing a product on the market' and 'processing material' is relevant here: the obligations under Article 27 of the ESPR apply to those placing the product as such in circulation, not to every link in the chain that handles the material. What a competent authority concretely requests therefore depends on what role a company fulfils in that chain.
No fixed date for aluminium yet, but a general framework in place
For aluminium it is not yet certain when the digital product passport will become mandatory. The delegated act required to regulate this for aluminium is expected around 2027 according to the ESPR work plan for 2025-2030; the obligation itself would have to enter into force after that, with a realistic target date around 2029. Both dates are not fixed until the delegated act is actually published. Until then, the general framework of Regulation (EU) 2019/1020 remains in force: market surveillance authorities can already now request documentation and information about products falling under existing EU legislation, regardless of whether a product passport already exists. Once the delegated act for aluminium is published, the date will appear here.
How this will be approached in practice
Those wishing to prepare for this should start by putting in order the technical documentation already relevant to the product: composition, origin, and the data the manufacturer or importer already collects for internal administration or for customers. Next, it is useful to determine the role the company plays — manufacturer, importer, authorised representative or distributor — because Regulation (EU) 2019/1020 describes different obligations and powers of the competent authority per role. Subsequently, following the ESPR work plan is the way to know when the delegated act for aluminium is published, so that the transition to a mandatory product passport does not come as a surprise. Finally, it is practical to think now about where the data will come from that must eventually appear in a passport — composition, origin, recycled content — because this data is often already present somewhere in the chain, only not yet bundled.
Where this comes from: 2019/1020 and Article 27 ESPR
The authority of a supervisory body to request documentation and information, and to verify whether a product complies with the requirements, derives from Regulation (EU) 2019/1020 on market surveillance and product compliance. The obligations of manufacturers to keep technical documentation, ensure compliance and — where applicable — make a digital product passport available, are laid down in Article 27 of Regulation (EU) 2024/1781 (ESPR). Which specific requirements will apply to aluminium, and from when, will be determined by the delegated act that still needs to be adopted for this product group.
Anyone who wants to know now which documentation a supervisory body can request for a specific aluminium product would be well advised to consult the text of Regulation (EU) 2019/1020 and Article 27 of the ESPR themselves via the links below, and to follow the publication of the delegated act for aluminium as soon as it appears.
What this is based on
- Regulation (EU) 2019/1020 (market surveillance and product compliance)
- Regulation (EU) 2024/1781 (ESPR), Article 27 (obligations of manufacturers)
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
An inspection sounds abstract until someone shows up at the counter, or until an email arrives requesting documentation. What a supervisory authority asks for in practice can be traced back to two regulations: Regulation (EU) 2019/1020 on market surveillance in general, and Article 27 of the ESPR (Regulation (EU) 2024/1781) on the obligations of manufacturers specifically for products that fall under a product passport. The combination of these two determines what actually happens on the ground when an inspection is carried out.
What is expected of you
Demonstrable product conformity
Regulation (EU) 2019/1020 is based on the idea that a market operator can demonstrate that a product meets the applicable requirements, rather than this being clarified only when a supervisory authority asks for it. For a company with 10 to 100 employees, this means that the substantiation of conformity must already be in place: technical documentation, test reports, declarations from suppliers on composition or origin. Anyone who starts collecting this only after a first request from a supervisory authority is playing catch-up.
A contact point within the organisation
Market surveillance works with a responsible market operator: someone who responds to questions and who can provide the requested documents. In a smaller company, this is often the same person who also manages quality files or procurement. In practice, this means there must be someone with the authority and knowledge to respond within a reasonable timeframe — not an external party who first needs to be brought in before anything comes back.
Information aligned with the product passport
Article 27 of the ESPR describes that manufacturers can substantiate the information that must appear in a product passport: where does the data come from, who provided it, and does it match what is in the passport. For aluminium semi-finished products, this includes data on composition, origin, and potentially recycling percentages. A supervisory authority consulting a passport via the QR data carrier can ask for the underlying source documents of that information. A company that passes on data without keeping its own copy of the substantiation cannot show anything beyond what is already online when asked.
Cooperation during an inspection
Regulation (EU) 2019/1020 is based on cooperation: providing access to information, making samples available if requested, and providing relevant documentation within a set timeframe. This requires an organisation that knows where the documents are and who can provide them, even if the person who created the passport is no longer with the company.
Action on a detected discrepancy
If a supervisory authority detects a discrepancy — a passport that does not match the physical product, or missing information — then according to Regulation (EU) 2019/1020 there should be a response: correct, supplement, or withdraw the product from the market if requested. For a product passport, this means there must be a process to amend or supplement a passport, not just to create it once and then leave it as is.
Where things go wrong in practice
The documentation exists, but no one knows where. Test reports and supplier declarations are there, but scattered across different folders, mailboxes and systems. When a supervisory authority asks, it takes days to gather everything together, while the request often needs to be answered within a shorter timeframe.
The passport and the physical product diverge. A supplier changes the composition of an alloy, but the passport is not updated. During an inspection, the data turns out not to match what is actually in the product.
No one is a contact point. The company has had the passport prepared by an external party, but internally there is no clarity about who responds when a question comes in. The email from the supervisory authority remains unanswered for days because no one feels responsible.
Supporting evidence of origin data is missing. A recycling percentage is stated in the passport, but the supplier's declaration on which that figure is based has never been archived. Without that source documentation, the figure has been published, but cannot be substantiated.
Stock that is already in circulation before the obligation takes effect is forgotten. An inspection sometimes focuses on products that have been on the market for longer. Anyone who has only prepared for new production and has not thought about what happens to aluminium stock that is already there when the rules take effect , may still be confronted with this during an inspection.
What you can document now
- An overview of who within the organization is the point of contact for questions from a supervisory authority, including a replacement.
- The source documents behind each piece of data in the passport: test reports, supplier declarations, certificates — kept in a fixed location, not only with the external party that compiled the passport.
- A fixed moment at which it is checked whether the data in a passport still aligns with the current product, especially after a change by a supplier.
- A brief procedure for what happens when a supervisory authority makes contact: who responds, within what time, and who provides the documents.
- For companies that still need to begin: an overview of how the product passport for aluminium is tackled step by step, so that the supporting evidence is in order from the outset rather than collected afterwards.
- For internal organization: a brief explanation to colleagues about what is changing, to be found at how do I explain to my colleagues what changes with the product passport, so that an inspection does not come as a surprise to people who are not prepared for it.
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.