Who is responsible for the product passport for aluminium?

The manufacturer creates the passport, alupas.eu provides the platform

The manufacturer of the aluminium semi-finished product is responsible for the product passport. This follows from Article 27 of the ESPR (Regulation (EU) 2024/1781): the manufacturer ensures that the passport exists, that the data in it is correct, and that the passport can be linked to the product via a data carrier such as a QR code. Anyone who places aluminium products from outside the EU on the European market acts as an importer and then has comparable responsibility: to verify that the manufacturer has drawn up the passport and that it is present before the product enters the EU market. alupas.eu is not a party that assumes this legal responsibility — the platform compiles the passport from the data supplied by the manufacturer or importer, hosts the passport, and provides the QR data carrier. The substantive accuracy of the data remains the responsibility of the person who supplies it.

For profiles, foundries and packaging aluminium — not for every link in the chain

This allocation of responsibility applies to the manufacturer or importer of the aluminium product itself: profile manufacturers, foundries and packaging aluminium producers fall under this once a delegated act enters into force for their product category. It does not apply to intermediaries who resell a product unchanged without placing it on the EU market as an importer, and it does not apply to the processor who purchases the aluminium semi-finished product to make a finished product from it — the latter has his own role as regards his own product, but not for the passport of the semi-finished product he purchases. It also does not yet apply to product categories for which no delegated act has been established: the ESPR itself only mandates a passport once a specific act regulates that for that product group. Aluminium semi-finished products do not fall under this yet.

No fixed date yet, but a set work plan

There is no fixed entry date for the product passport for aluminium yet. The work plan of the European Commission for the ESPR (2025-2030) mentions a delegated act for 2027, but this is a schedule, not law. Only once that act is published will it be clear which aluminium products are subject to the requirement, which data are mandatory, and from which date. Until then, the general structure of Article 9 and Article 27 of the ESPR already applies as a framework — those articles describe what a digital product passport looks like and who is responsible for it — but without a delegated act for aluminium there is no concrete obligation to draw one up yet. Once that act is in place, the date on this platform will be updated.

What a manufacturer or importer can prepare now

The first step is to determine which role applies: manufacturer of the aluminium semi-finished product in the EU, or importer of a product from outside the EU. That role determines who will be responsible for the accuracy of the data. The second step is to inventory which data about the product are already available — origin of the material, alloy, recycling percentage, processing history — because this type of data is expected to form the core of an aluminium passport. The third step is to establish who in your own organisation or supply chain manages this data, so that a search is not needed once the delegated act is published. The fourth step is to keep the role allocation with a platform such as alupas.eu clear: the platform compiles and hosts the passport, but the manufacturer or importer remains responsible for the accuracy of the data supplied. Whoever has these points in order will not be left empty-handed once the obligation comes into effect.

The legal basis: Article 27 and Article 9 of the ESPR

Article 27 of the ESPR (Regulation (EU) 2024/1781) describes the obligations of manufacturers, including ensuring a correct and up-to-date product passport. Article 9 of the same regulation describes what a digital product passport contains: which data must be included, how it must be accessible, and what role the data carrier — such as a QR code — plays in this. Both articles form the general framework of the ESPR and apply to product groups once a delegated act concretely implements that framework. For the exact product groups, data fields and data that will apply to aluminium, the delegated act itself is the source once it is published.

Those who wish to prepare now can put their own product data in order and map out the division of roles with suppliers and customers — once the delegated act for aluminium is published, the concrete obligation and the entry into force date will be stated here.

What this is based on

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

The ESPR places the responsibility for the digital product passport primarily with the manufacturer. Article 27 of the ESPR (Regulation (EU) 2024/1781) sets out a series of obligations that rest with the manufacturer. Who precisely qualifies as a manufacturer is not always immediately clear in every situation — a company that has aluminium profiles produced and affixes its own brand to them may fall under this definition without operating a single machine. See also on this point Am I an importer or manufacturer according to the ESPR?

Having the passport drawn up and submitted

Article 9 of the ESPR (Regulation (EU) 2024/1781) describes what a digital product passport must contain and how it must be accessible, via a unique carrier such as a QR code. For a company with 10 to 100 employees, this means in practice that someone within the organisation must gather the source data: alloy composition, material origin, process data, recycled content. That person need not technically build the passport themselves — that can be outsourced — but the data must be correct and complete at the time of submission.

Ensuring the passport remains with the product

The obligation does not end with the creation of the passport. The data carrier must remain associated with the product as long as the product is on the market and must remain accessible for a period thereafter. For an aluminium semi-finished product that travels through multiple supply chain links (wholesale, processor, end customer), this means the QR code or similar carrier must not disappear somewhere along the way — for example because an intermediary repackages or modifies the product without passing on the data carrier.

Keeping data current and accurate

Manufacturers are expected to be able to substantiate the accuracy of the data in the passport. This requires a process in which changes in the production process — a different alloy, a different raw material supplier — are also reflected in the underlying data. In an organisation of this size, this typically falls to the same person or department that also manages quality documentation, since the sources often overlap.

Making data available for supervision

The manufacturer must be able to present to the competent authorities the data underlying the passport. This is not an obligation that only applies at the moment of an inspection; it requires record-keeping that is searchable at any time, even years after a specific batch of aluminium has been supplied.

Where things go wrong in practice

A first situation where things often go wrong: a company thinks it is purely acting as a supplier and that the responsibility lies with the customer, while the aluminium is placed on the market under its own article number and its own specifications. A company supplying aluminium to a brand owner who sells it under its own name faces a similar question — see who is responsible for the passport if I supply aluminium to a brand owner.

A second situation: the manufacturing data is scattered across multiple systems — ERP, quality control, procurement — and no one has ever brought them together in a single file. When the passport has to be drawn up, it turns out that the origin of part of the raw material can no longer be reconstructed.

A third situation arises with companies with facilities in multiple EU countries, where it is unclear which facility carries which part of the obligation. This applies particularly when production and sales are divided across different countries — see who is responsible for the passport if I produce in multiple EU countries.

A fourth situation: a company switches suppliers for part of the raw material, without the implications for the ongoing passport being mapped out. This directly relates to the question what must I arrange for the passport if I change supplier, as a different origin may require different data in the passport.

A fifth situation: the manufacturer is located outside the EU, and within the EU organisation there is a belief that the obligation thereby automatically rests with the importer without this ever being concretely agreed. See on this point My manufacturer is outside the EU — who arranges the digital product passport then?

What you can document now

An overview of which members of the organization supply which source data for the passport (composition, origin, process data), including a replacement in case of absence.
A written agreement with suppliers on which data they provide and in what form, so that the basis for the passport does not rely on loose emails or verbal commitments.
A file per product line or alloy in which the underlying documentation (test results, certificates, certificates of origin) is kept alongside the passport itself, so that the accuracy of the data can be demonstrated at any time.
A documented procedure for what happens when raw material, process or supplier changes: who reports this, and who updates the passport.
An overview of the role that the organization itself plays — manufacturer, importer, distributor — with the substantiation for it, especially when the aluminium goes further to the market via intermediaries or under a different brand. Those who have doubts about this from the trading side will find more about their own position at What obligations does a distributor or trader of aluminium have?

These records are supported by our templates as a starting point: a data collection form per product line, a model agreement with suppliers on data provision, and a checklist for the file that belongs with each 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.