alupas.eu

Which data go into the product passport for aluminium?

The content of the digital product passport is determined by the delegated act, which does not yet exist for aluminium

There is currently no established list of data that must specifically be included in the digital product passport for aluminium semi-finished products. However, the ESPR (Regulation (EU) 2024/1781) establishes the framework in Article 10: the passport contains information on the product, the materials and substances it contains, its origin, its performance and end-of-life, linked to a unique identification and disclosed via a data carrier such as a QR code. Which specific data apply to aluminium profiles, castings or packaging material will be worked out per product group in a delegated act based on the ecodesign requirements in Articles 5 to 7. This elaboration for aluminium does not yet exist.

For whom this framework applies, and what remains open

The framework of Article 10 applies to products falling under the ESPR once a delegated act has been adopted for their product group. For aluminium semi-finished products — profiles, castings, packaging aluminium — this step has not yet been taken. This means that the categories of information mentioned in Article 10 (product identification, material composition, substances of concern, performance and sustainability data, information on repair, reuse and recycling) form a framework, but the precise fields, units of measurement and mandatory answers for aluminium still need to be established. What cannot therefore be inferred here: a ready-made checklist with exactly the data that an aluminium profile manufacturer will have to provide in future. That will only come with the sector-specific act.

When the dataset is finalised, and what applies in the meantime

There is no fixed date for the delegated act for aluminium. According to the ESPR work plan 2025-2030, this act is expected in 2027; once it is published, the date and content of the dataset will be stated here. Until then, there is no mandatory dataset for aluminium under the ESPR. This does not mean there is nothing to do: the general structure of Article 10 and the type of information mentioned in Articles 5 to 7 (performance, environmental characteristics, recycled content, presence of substances of concern) already provide a good indication of the direction in which sector-specific requirements will develop.

What a manufacturer or importer can prepare now

The order in which this is usually tackled begins with mapping what data already exists: alloy composition, origin of the aluminium (primary or secondary), proportion of recycled material, certificates from suppliers, and any test reports on mechanical properties. These data appear in virtually every implementation of Article 10, because they directly relate to the information requirements in Articles 5 to 7 on environmental performance and material use. A second step is to enquire of suppliers whether they can provide this data in a structured manner at individual product level, rather than as a general factory declaration — the passport operates at product level, not at batch level in a general sense. A third step is to record this data in a system that keeps it accessible over an extended period, since the passport must remain available for a period after the requirements are adopted. Anyone who organises this now will not have to start from scratch when the delegated act is published, but can enter the existing data into the fields that will then apply.

What this is based on: Article 10 and Articles 5 to 7 of the ESPR

Article 10 of the ESPR (Regulation (EU) 2024/1781) describes the general requirements that a digital product passport must meet: what types of information it should contain, how that information is made accessible and to whom. Articles 5 to 7 of the same regulation determine the ecodesign requirements — the performance and information requirements — which are established per product group via a delegated act and which subsequently determine the content of the passport for that product group. Because no delegated act has yet been published for aluminium semi-finished products, the exact dataset for this sector has not yet been established; however, the framework of Article 10 and the nature of the requirements in Articles 5 to 7 indicate where that elaboration will align.

If you wish to start now, it is advisable to collect and structure existing data on composition, origin, recycled content and certification at product level, and to monitor the publication of the delegated act for aluminium in order to subsequently integrate that data into the definitive dataset.

What you must concretely do

The Digital Product Passport is not a loose document with freely fillable fields. The ESPR (Regulation (EU) 2024/1781) specifies in Article 10 what requirements the passport as a whole must meet, and in Articles 5 to 7 which product information may be included in it. For aluminium, the precise content only becomes concrete once the delegated act for this product group has been published. What can already be described now is the nature of the data that logically belongs in that passport, based on what the regulation refers to as categories.

What is expected of you

Record material identification

A product passport revolves around traceability: what exactly is this material, and where does it come from. For aluminium, this means in practice a link between the physical product and the alloy designation. A company with 10 to 100 employees usually already has this data in their own production specifications or supplier certificates; the task is mainly to get them into a structured, digitally readable form. How that designation is precisely recorded is described under how do I record the alloy and the EN-AW designation?.

Show origin and composition of the material

In addition to the alloy itself, it is about the composition of the aluminium: what part is primary aluminium, what part is recycled material. This is one of the data points that the ESPR explicitly aims at through the information requirements in Article 7, because circularity is a central objective of the regulation. For a foundry or profile company, this means that their own purchasing records and melting records will play a role in substantiating this percentage. The way in which that proportion can be demonstrated is detailed under how do I demonstrate the proportion of recycled aluminium?.

Include environmental impact of the product

Articles 5 and 6 of the ESPR focus on ecodesign and performance requirements, including the climate impact of a product. For aluminium, the focus here is mainly on the CO2 emissions associated with production. This is one of the more demanding aspects to substantiate, because it requires data on energy consumption and processes that are not always already standardised within a mid-sized production company. See how do I demonstrate CO2 emissions per tonne of aluminium?.

Specify surface treatment and finishing

Aluminium semi-finished products are often anodised, coated or otherwise finished before they reach the end user. This is relevant to the passport because treatment affects recyclability and the way the material can be processed at the end of its life. For companies that carry out treatment themselves, this means that the process data from the treatment step also become part of the documentation that feeds the passport. More information on this is available under must I report the surface treatment of aluminium?.

Include repair and processing information

Part of the information requirements in the ESPR focuses on what happens to a product at the end of its life: is it repairable, how is it separated, what residual materials are generated. For aluminium semi-finished products, this is less a question about repair of the end product, and more a question about how the material returns to the recycling chain. This section is further explained under must I include information about repair and residues from aluminium in the passport?.

Keep data up to date

A passport is not a snapshot that is filled in once and then left as it is. The ESPR requires a living link between product and data, which means that data that changes — such as an adjusted recycled content percentage for a new production batch — must also be reflected in the passport. How often that is necessary is described under how often must I update the data in the product passport?.

Where things go wrong in practice

A few situations regularly come up in the compilation of an aluminium passport.

Alloy data that does not match the batch. An profile manufacturer supplies under a single EN-AW designation, while the precise composition varies slightly per melting charge. Without a clear link between charge data and passport, there is a mismatch between what is stated on paper and what is actually delivered.

Recycled content percentage based on an average rather than the specific product. Some companies calculate using an annual average across their entire production mix, while the passport is linked to a specific product or delivery. That difference between "average" and "for this product" leads to discussion once someone wants to substantiate the figure.

CO2 figures that are not substantiated with a documented measurement method. A figure without a clear calculation method behind it is difficult to defend. Which method is customary to apply in this respect is described at according to which method should I measure the values for the passport?.

Surface treatment that is overlooked because it is carried out by a third party. When anodising or coating is outsourced, that information sometimes disappears from view when compiling the passport, while the end user of the aluminium does expect data on this.

Confusion between the technical file and the passport. Some companies think that what is already in the technical file is automatically sufficient for the passport. The difference between these two documents is explained at what is the difference between my technical file and the digital product passport?.

What you can document now

  • An overview per alloy and EN-AW designation, linked to the production batch to which it applies
  • Documentation of the origin of raw material: share of primary aluminium versus recycled content, per product or delivery
  • A documented calculation method for CO2 emissions per tonne, including the data on which that calculation is based
  • Process data of any surface treatment, also when this is carried out by a third party
  • An internal process for keeping data current when there are changes in composition or process
  • An overview of who within and outside the organisation has access to which data from the passport, also relevant in light of who may view which data from the product passport?

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.