No, a small batch or custom-made product does not in itself constitute an exception to the aluminium product passport. The regulation ties the obligation to the type of product and to who places it on the market, not to the number of units you produce. A foundry that supplies ten custom-made parts is in principle subject to the same rules as a foundry that supplies ten thousand.
That does not mean exceptions never arise. For specific product groups, the precise rules are laid down in separate delegated acts, and they may well contain thresholds or exceptions, for example for prototypes, spare parts or one-off productions. At the moment, it has not been published for aluminium semi-finished products whether such exceptions will apply. As long as that text is not available, the safest assumption is that the main rule applies: the product determines whether a passport is needed, not the size of the order.
Why batch size is not the first question
The regulation is built around product categories, not around production volumes. For each category, the information that must be included in the passport and when the obligation takes effect are determined separately. Aluminium semi-finished products form such a category. Within that category, the text makes no distinction between a manufacturer that produces in bulk and a manufacturer that works on order. Anyone wondering whether their product falls under the definition first reads what exactly is meant by "aluminium" and by the product group in question, and only then whether anything specific for small series is regulated.
What does count: your role in the supply chain
What is decisive is the role you perform. If you are the manufacturer or importer who places the product on the EU market for the first time, you are generally responsible for the passport, regardless of the batch size. If you are a distributor, installer or processor of a semi-finished product that has already been placed on the market by someone else, that responsibility usually lies elsewhere in the supply chain. For many companies, this distinction is harder to determine than the batch size itself, and therefore deserves more attention than the question "how many units do I produce". In the knowledge base by situation you will find the concepts that determine this role distribution, explained without legal jargon.
Custom-made products and prototypes: what is not yet established
For some product groups within the broader ecodesign regulation, exceptions are mentioned for one-off or very small productions, such as prototypes not placed on the market. Whether something like this will also apply to aluminium semi-finished products is not yet settled. That will only become clear once the delegated act for this product group is published. Until then, it is not possible to say with certainty that custom-made work or a limited batch exempts you from the obligation. Anyone who needs clarification on this for their own situation should contact a lawyer or the competent supervisory authority; we will update this site when the official text changes.
What this means for an installation company or small foundry
An installation company that has aluminium profiles custom-made for a single specific project is usually not a manufacturer within the meaning of the regulation, but a user of a product that someone else has placed on the market. A small foundry that casts parts itself and supplies them directly to customers may well be the manufacturer, even if it is a single custom-made part. The difference therefore does not lie in the batch size, but in the question of who makes the product available on the market for the first time. That is precisely the kind of question many SMEs wonder about, and where a brief check provides more clarity than an assumption based on company size.
How you verify this for your own situation
Because the outcome depends on the product, your role in the chain and any future exemptions, a general rule of thumb is not advisable. A practical first step is getting an indication of your situation in a few questions. That scan does not replace legal advice, but does show which elements are relevant for your company and where you need to read further. If you still have doubts after that indication, then look at the frequently asked questions about scope and exemptions or put the question to a lawyer.
If you want to know how we build up the information on alupas.eu and where the data comes from, you can read that on the page that explains where our information comes from. If you want to immediately see where your company stands, do the free quick-scan or browse through the knowledge bank; both give you without obligation a first, concrete starting point.