Whether the digital product passport for aluminium also applies to your company does not depend on your turnover or the size of your inventory, but on your role in the supply chain. Those who purchase aluminium profiles, castings or packaging material and resell it unchanged generally have a lighter obligation under product regulations than the party that places the product on the EU market for the first time. As soon as you change anything about the product or packaging, or import it yourself from outside the EU, your role may shift.
In practice, this means that a pure reseller usually has to check whether the passport is present and readable, without having to supply the data themselves. As soon as you start repackaging, put your own brand on the product, or source material directly from outside the EU, you count in most product regulations as the party responsible for the content of the passport. The official text of the regulation sets out these roles; the precise application for aluminium will follow once the implementing rules have been published.
What the regulation means by "placing on the market"
The moment when a product first becomes available within the EU is usually the reference point for obligations under product regulations. Not the location where you are established, and not the number of parties through which the product subsequently passes. A manufacturer or importer who first offers the aluminium in the EU generally bears responsibility for compiling the passport. A distributor who subsequently only passes the product on acts as a link in the chain, not as a source of the data.
When you are considered a pure reseller
If you purchase aluminium products from a manufacturer or importer within the EU, pass them on unchanged, and change nothing about them — no new packaging, no own brand, no processing — then responsibility for the passport generally remains with the party that originally placed the product on the market. Your role then often limits itself to passing the QR data carrier on to your own customer and flagging if a passport is missing or no longer correct.
It is this distinction that many entrepreneurs in practice miss, because "I only pass it on" feels non-binding, whereas the question that matters is a different one: do you change anything about the product or packaging, and where do you source the material. in a few questions to see which role fits your company gives an initial indication there, regardless of what your contract or invoice says.
When your role does shift
There are a few situations in which a party that sees itself as a trader is in practice treated as a manufacturer or importer. This applies, for example, when you import aluminium directly from outside the EU and are the first party to offer it within the EU, when you sell the product under your own name or brand, or when you process it, repackage it or combine it with other materials before it moves further down the supply chain. In those cases, responsibility for compiling and keeping the passport current often lies with you, even if you did not manufacture the aluminium yourself.
Because this distinction can vary from situation to situation and the implementing rules for aluminium have not yet been finally established, it is wise not to rely on instinct in case of doubt. The knowledge base with the roles explained per situation sets out the different positions in the supply chain alongside each other, each with the source in the official text.
What this means for the practice of your company
For an installation company that purchases aluminium profiles and processes them in its own construction, the question differs from that for a wholesaler that passes on pallets unchanged. For both, however, it is useful to map now who you source the aluminium from, whether a passport is supplied with it, and whether you change anything about the product yourself before it reaches your customer. That overview is also the basis on which a software supplier or passport service can later connect, without you having to figure out afterwards which role belongs with which product.
If you want to see how we use that overview to compile a passport from the data of the manufacturer or importer, read on how the data for a passport are collected and hosted the steps involved. For your own situation, especially if in doubt about the exact role your company has, it remains advisable to have this verified by a lawyer or the competent supervisory authority.
Would you like an initial indication for your own aluminium products, without having to immediately build a file for it? The free quick-scan on the most frequently asked questions about the aluminium product passport and the product scan provide an initial direction in a few minutes, with the reference to the official text included.