Which data must I request from my aluminium supplier?
Basic data: material, origin and recycled content
For the digital product passport for aluminium, there are essentially four types of data at stake: the material composition (alloy, additives), the origin of the aluminium (primary or secondary, country of production), the percentage of recycled material, and the presence of substances of concern (such as substances on the candidate list of substances of very high concern). In addition, it is customary to request data on the production method, any certificates (such as ASI or comparable chain certification) and technical properties relevant to sustainability, such as reprocessability and expected service life. Which data exactly will be mandatory for aluminium is not yet fixed because the product-specific implementation (the delegated act) has not yet been published. The categories above follow from what the ESPR generally requires of a digital product passport, and are therefore a good basis for requesting them from a supplier now.
Who this applies to and what is excluded
This question is relevant for those who purchase aluminium semi-finished products and are themselves responsible for compiling a product passport — think of manufacturers of profiles, foundries and processors of packaging aluminium who source the base material from a supplier. These are data that the manufacturer or importer themselves cannot measure or determine, but which come from an earlier link in the chain. This does not apply to companies that merely resell an end product without their own processing, nor to raw materials or materials outside aluminium — each material group will receive its own implementation within the ESPR. Nor does this yet apply as a concrete obligation: as long as no delegated act for aluminium has been published, there is no legal obligation to collect this data. What does already exist is the general obligation for actors in the supply chain to provide accurate and up-to-date information whenever a product passport is requested from them.
No fixed date yet: the ESPR work plan 2025-2030
There is no fixed start date yet for the obligation to provide or request this data. According to the ESPR work plan 2025-2030, the delegated act for aluminium is expected in 2027; only after its publication will a concrete deadline follow for when the passport and the associated data request become mandatory. Until then, nothing legally changes in the existing purchasing relationship with a supplier. What you can do now: incorporate the data mentioned above into regular correspondence or purchasing terms, so that when the act is published, you do not have to retrieve them all at once from suppliers who may not be prepared for it by then.
How to approach this, step by step
The practical sequence begins by mapping the suppliers providing aluminium raw material or semi-finished products, and distinguishing between primary and secondary aluminium in that supply. Next, it is useful to check with each supplier which data are already available — many suppliers already have certificates on origin or chain of custody, or already provide the recycled content percentage in their own documentation. This is followed by the question of data that are still missing: the exact alloy composition, any presence of substances of concern above a threshold value, and information on the production process that is relevant to environmental impact. It is prudent to document this request in writing, so that there is a record of what was requested and when, and so that a supplier knows that these data will be needed on an ongoing basis — not as a one-off action, but as a permanent part of the supply. Finally, it is practical to check whether a supplier already works with a format or system in which these data are maintained, so that integration with a future product passport is simpler.
The legal basis: Article 38 and Article 10 of the ESPR
That suppliers must provide data to whoever is compiling a product passport follows from Article 38 of the ESPR (Regulation (EU) 2024/1781), which sets requirements on actors in the supply chain to provide correct information. Which data a digital product passport must contain in general terms is set out in Article 10 of the same regulation; that article forms the basis for the categories mentioned above (composition, origin, recycled content, substances of concern). The precise, aluminium-specific list of mandatory data will follow only from the delegated act which has not yet been published.
Whoever wishes to engage with a supplier now can best start by requesting the four basic categories from this article and documenting which data are already available and which are not. Once the delegated act for aluminium has been published, the definitive, mandatory data list and the corresponding date will be added here.
What this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 38 (requirements for actors in the supply chain)
- Regulation (EU) 2024/1781 (ESPR), Article 10 (requirements for the digital product passport)
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
A product passport does not come out of thin air. The data it contains — alloy composition, origin, recycling percentage, process information — must come from somewhere, and that place is usually the supplier. Article 38 of the ESPR (Regulation (EU) 2024/1781) establishes that actors in the supply chain must provide the information necessary to comply with the requirements of the regulation. For a company that purchases and processes aluminium, this translates into a number of concrete expectations towards its own suppliers.
Request the alloy composition
The basis of every passport is the material composition: which alloy, which additions, which percentages. Without this data, there is no passport to complete. For a mid-sized company, this means that the purchasing department receives not only a delivery note or invoice, but also a material certificate or similar document in which the alloy is traceable. This should be a standard part of every delivery, not something to be requested afterwards.
Request information on the share of recycled material
Article 10 of the ESPR describes that the digital product passport must contain information on, among other things, the sustainability characteristics of the product — of which the share of recycled material plays an important role. A supplier that supplies aluminium that partly consists of scrap must be able to substantiate that share. For companies that work with mixed batches this is often the most difficult point: the percentage is not always exact, but must be established in a traceable manner.
Request information on the origin of the material
Origin says something about where the raw material was extracted or where the scrap was collected, and that touches on both environmental data and any import obligations. Companies that source aluminium from outside the EU face an additional layer here; see what the product passport means when importing from outside the European Union. It is also advisable for European suppliers to include origin as a standard question in the request, not as an exception.
Request process information that is relevant for the digital product passport
In addition to composition and origin, the digital product passport can also contain process-related information, such as the method of production or processing, insofar as it is relevant to the sustainability characteristics mentioned in Article 10. For a company of this size, it is practical to make this question standard with new suppliers, so that it does not have to be requested again later, under time pressure.
Inquire with subcontractors in the chain
When part of the aluminium is processed by a subcontractor before it reaches you, it is worth knowing whether that subcontractor has also provided or must provide data. This is elaborated on the page about whether a subcontractor processing aluminium must also provide data. For your own administration, it is useful to know in advance who in the chain manages which information, instead of discovering this only when the digital product passport must be compiled.
Where things go wrong in practice
In practice, the data collection often gets stuck on a few fixed points.
A common situation is that the supplier sends an invoice and a delivery note, but no material certificate — because this was never agreed upon. The company only discovers this when the digital product passport must be compiled, and by then the delivery has long been processed in its own production process.
Another situation: the aluminium comes from a batch that is composed of multiple batches, each with a slightly different alloy composition. The supplier provides one average figure, without indicating how that average was calculated. For the buyer, that figure can no longer be traced back to the original batches.
Also tricky: a supplier delivers part of the aluminum via an intermediary who does not themselves have the source data. The question "where exactly does this come from" is then passed from party to party, without anyone being able to provide a complete answer.
Furthermore, it happens that a supplier does have the requested data, but does not send it as standard — it has to be requested again each time, per order, which costs time and is error-prone.
And sometimes it only becomes clear late in the process that a supplier structurally cannot or will not provide the data, for example because their own administration is not set up for it. For that situation it is useful to know what to do if a supplier does not provide the data.
What you can document now
To prevent these situations, it is practical to establish a number of things structurally instead of arranging them anew per delivery:
- A fixed set of data per delivery: alloy composition, share of recycled material, origin and relevant process information, each time in the same format.
- An agreement in the purchasing contract about which data the supplier provides and in what form. See for this the explanation about agreements on the delivery of passport data in the purchasing contract.
- A fixed inspection upon receipt from the data, so that deviations become apparent early rather than only when compiling the product passport. The approach described under helps with this how you verify your supplier's data for accuracy.
- An overview of subcontractors and intermediaries in the chain, with a note on who manages which data or should supply it.
- A procedure for mixed batches, in which how an average composition is calculated and which underlying data is retained is laid down.
- An established approach for the case where source data is missing, so that each time it does not have to be worked out again what is then possible; see also the page on what to do if the origin of the aluminium cannot be traced.
It is best to establish these agreements before the product passport actually has to be compiled. A supplier who knows in advance which data are routinely requested can arrange his own administration accordingly — which considerably reduces the risk of delays or missing information.
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.