The obligation for a digital product passport comes from a European regulation. That regulation governs the placing on the market of products within the European Union. If you also sell aluminium products to customers outside the EU, the obligation does not automatically apply in the same way there: the country of destination then determines its own rules, and these can be very different from what is presented here.
That does not mean the passport is without significance upon export outside the EU. As soon as a product is also, or simultaneously, sold within the EU, the obligation for that part remains in place. And for countries outside the EU, the customer or local law may request its own documentation, which sometimes resembles the European passport and sometimes stands entirely apart from it.
What the regulation was designed for
The regulation was drawn up to make products circulating within the European internal market traceable and comparable. The scope is therefore linked to placing on the market within the EU, not to the place where a product is manufactured or the nationality of the manufacturer. A Dutch company sending aluminium profiles to Germany is subject to the same rules as a company supplying directly to a Dutch customer. Once the destination lies outside the Union, the question shifts to the law of that country. In the knowledge base with explanations per situation you will find the background to this distinction between EU and non-EU, elaborated on the basis of the official text.
When you sell both within and outside the EU
Many companies supply multiple markets simultaneously: part of production goes to customers within the EU, another part to, for example, the United Kingdom, Switzerland or countries outside Europe. In that case, it is worthwhile to structure the data collected for the passport so that it remains usable for both situations. The origin, the alloy, the composition and the processing of the aluminium are data that can also be relevant outside an EU context, for example for customs, for your own quality documentation or for a customer who must themselves meet stricter requirements. With a short scan that shows where you currently stand you gain insight into which data you already have and which are still missing, regardless of the destination.
Countries that do not automatically participate
Outside the European Union, other regimes apply. Some countries closely linked to the internal market, such as EEA countries, generally adopt EU regulations at some point, but often with their own timeline and their own additions. Countries without such a link, such as the United Kingdom after Brexit or countries outside Europe, have an entirely separate framework for product information and documentation. Whether, and on what timeline, they introduce a comparable obligation is not yet determined and is up to the legislator of that country. For your own situation regarding exports to a specific country, enquiry with the local supervisory authority or a lawyer familiar with the law of that country is the appropriate course; this is not a determination that this regulation or this platform can provide.
What this means for your administration
Regardless of where a product ultimately ends up, it is practical to maintain the underlying data in one place: origin, composition, processing and the documents that go with it. This prevents you from having to determine afresh for each market which information already exists. Alupas.eu compiles the passport on the basis of the data you supply as a manufacturer or importer, and hosts it for ten years together with the QR data carrier. How that process works in detail and where the underlying information comes from can be read on the page that shows the process step by step.
What is not yet fixed
The delegated act that must lay down the precise requirements for the aluminium product passport is expected in 2027 according to the current work plan; the own compliance obligation for aluminium is currently expected around 2029, but that date is not yet fixed. How this regulation relates to legislation in countries outside the EU has likewise not been clarified, and it is not possible to predict whether, and how, other countries will follow suit. As soon as more is known about this, it will be added here.
Do you have questions about your own situation, for example because you supply both within and outside the EU? Then check the most frequently asked questions about the product passport or take the free quick-scan to see which data are already relevant for your products.