A mistake that regularly occurs among companies working with aluminium: they think that CE marking and the future digital product passport solve the same problem, or that arranging one makes the other unnecessary. This is not so. CE marking says something about the safety of a product for use. The digital product passport concerns the composition, origin and recyclability of the material, and falls under different legislation with a different purpose.
The confusion is understandable. Both feel like 'something that must be required on or with the product', both are often mentioned in the same breath with aluminium semi-finished products, and both require data that already exists somewhere in the company. But those who assume that one obligation replaces the other run the risk of ending up with a gap in the documentation while feeling that everything is in order.
Where the confusion comes from
CE marking has existed for some time and is a familiar part of the process for many companies: a declaration by the manufacturer or importer that a product complies with the applicable safety requirements, laid down in product safety rules that vary by product group. The digital product passport stems from the European regulation on ecodesign (ESPR) and is not about whether a product is safe, but about what is in it and what can happen to it at the end of its life.
Both processes can also request similar basic data, such as material composition or the name of the manufacturer. This fuels the idea that it is one and the same administrative flow. In practice, these are two separate obligations, each with its own legal basis, its own supervisory authority and its own way in which the information reaches the user.
What CE marking does and does not cover
CE marking states that a manufacturer or importer declares that a product complies with the applicable European safety directives. It says nothing about the environmental impact of the material, the origin of the raw material or the possibility of recycling. If you only have a CE declaration in order, you have therefore not collected data on the points that the digital product passport does ask for.
What the digital product passport adds to this
The digital product passport is aimed at traceability and circularity: which aluminium alloy was used, where does the material come from, and how can it be processed at the end of its life. This information is disclosed via a QR data carrier on the product, not via a marking as with CE. The precise obligations per product group are laid down in delegated acts under ESPR, and for aluminium these have not all been published at this time. Those who want to see which concepts belong to this and how they relate to each other will find an overview in the knowledge bank with the concepts listed.
The consequences of this mistake in practice
The risk of this confusion does not lie in CE marking itself — it does not change due to the arrival of the product passport — but in the assumption that the existing CE file is already sufficient. Data on alloy composition or origin that has been recorded for CE purposes is often not in the form or completeness that the passport will later require. Companies that only discover this when the obligation becomes concrete have less time to request data from their suppliers. You can get a first impression of where your company currently stands in five questions see where you stand.
How to keep the two processes separate
It helps to keep the two obligations administratively separate within the company as well: separate responsible person, separate file, and no assumption that one automatically covers the other. It is useful, however, to check which data overlap, so they are not collected separately twice. How such a file for the product passport is built from the data you already have is explained on the page where the information in the passport comes from. For questions about the precise delimitation between product safety rules and the ESPR, the official text and the competent supervisory authority provide clarification, not this article.
Do you have a similar question about how the product passport relates to rules you already know? Check the answers to similar questions or take the free quick-scan to see which topics are relevant for your company.