in which language must the data in the product passport be presented

What you must concretely do

What is expected of you

The ESPR regulates in Article 10 what must technically and substantively appear in the digital product passport, but the regulation itself contains no concrete prescription on the language in which the data is ultimately presented to the user. This is no accident or oversight: in the ESPR system, the language issue is typically addressed through delegated acts for each product group, as Articles 5 to 7 of the ESPR also indicate that precise information and performance requirements are to be worked out per product category. For aluminium semi-finished products, that delegated act does not yet exist, and therefore the language provision is not yet established.

This does not mean there is nothing to be said about how a company can prepare for this. A few practical lines can already be drawn now.

Record data in a reusable, language-neutral form

What can be done now: record data on the alloy, composition and origin in such a way that it is not tied to one language. Codes, figures and standardized designations (such as an EN-AW designation, see how you record the alloy and the EN-AW designation) are by nature language-independent. Free text fields — an explanation of a surface treatment, a note about the origin of scrap — are not. For a company of 10 to 100 employees, this is primarily a matter of discipline in their own administration: use a code or standard wherever possible instead of their own description, so that translating later requires less work.

Build multilingualism into the source document, not only at publication

Undertakings supplying in multiple Member States would be well advised to already consider now which data must be able to be supplied in multiple languages. This applies in particular to explanatory information, not to core figures such as the share of recycled material (see how the proportion of recycled aluminium is demonstrated) or CO2 emissions per ton (see how CO2 emissions per tonne of aluminium are demonstrated), which are usually represented as figures. For a smaller company, this primarily means: when preparing technical documentation, already taking into account that part of it may one day need to be available in multiple languages, instead of discovering this only afterwards.

Distinguish between the technical file and what appears in the passport

The language of the internal technical file and the language of the publicly visible product passport are two separate questions. A technical file is often drawn up in the working language of the enterprise or the factory; what appears in the passport is intended for a broader public — from competent authority to customer in another Member State. The difference between those two documents, and why they are not one-to-one identical, is described on the page on the difference between the technical file and the digital product passport. For the language question, it is particularly relevant that an enterprise should not be surprised by the idea that the passport automatically appears in the same language as the internal file.

Where things go wrong in practice

A few situations in which the language question causes confusion in practice, even though the ultimate rule is not yet settled:

A manufacturer supplies profiles to customers in three Member States and assumes that one language version of the technical documentation is sufficient because the customer will read English anyway. This is an assumption about what a competent authority or end-user in another Member State will accept, and not something about which there is already certainty now.

An importer of packaging aluminium takes the source text from a foreign supplier literally in the passport, including free text fields on surface treatment (see whether surface treatment must be reported), without translation or verification of the content having taken place. When in doubt about what a customer needs, the distinction between what must be substantively included in the passport and in which language that happens are two separate questions that do not automatically coincide.

A foundry outsources the preparation of passport data to a service provider and assumes that the service provider will arrange the translation as well, without this being recorded anywhere. As soon as this is not agreed, a gap arises between what is expected and what is delivered.

An enterprise assumes that, because CBAM obligations (see what CBAM means for the import of aluminium) are handled in a particular language, the same automatically applies to the product passport. These are two different regulations with their own framework, and a language choice in one system says nothing about the other.

An enterprise drafts the free text fields on repair information (see whether information on repair and residues must be included in the passport) in an informal, strongly company-internal writing style, which makes translation afterwards unnecessarily difficult because technical terms and abbreviations are not one-to-one translatable.

What you can document now

In anticipation of the delegated act, it is practical to organize a number of matters internally now:

• An overview of which data in the passport consist of standardized codes or standards (such as alloy designations) and which consist of free text, so that it is clear where a possible translation step will be needed.
• An agreement with suppliers and service providers about who is responsible for the language of the supplied data, including when that will be checked.
• A fixed, reusable wording for recurring explanations (for example on surface treatment or the origin of scrap), so that a later translation does not have to be prepared anew each time.
• A log of the source of each item of data, including in which language the original was supplied — useful when reconstructing what was entered and when, and relevant in connection with the question how often the data in the product passport must be updated.
• An internal overview of who may access which data from the passport, which helps to distinguish between what becomes publicly visible and what remains internal; see also who may view which data from the product passport.

Once the delegated act for aluminium has been published, it will be supplemented here which language or languages are concretely prescribed for the passport.