The short answer
Whether the digital product passport applies to your company depends first and foremost on what you do with aluminium, not on whether you work with it daily. The regulation targets whoever places a product on the European market for the first time: the manufacturer or importer of aluminium semi-finished products. If you only use aluminium products further in your own work, for example as an installer fitting window frames or pipes, you are usually not the one who must supply the passport.
That does not mean the subject will never affect you. A client or supplier may ask you about it, and in some supply chains the question of who is responsible for the data shifts. It is therefore useful to know exactly where the boundary lies, even if you are probably not the supplier yourself.
What the regulation means by "placing on the market"
The core of the ESPR regulation (the European regulation on ecodesign for sustainable products) is that obligations arise the moment a product becomes available on the European market for the first time. For aluminium, this concerns semi-finished products: profiles, castings, sheets, foils and similar products that serve as raw material for further processing. Whoever manufactures such a product or imports it from outside the EU is in principle the one who deals with the passport.
Whoever buys a ready-made end product in which aluminium is incorporated does not place that aluminium on the market themselves; the manufacturer of the semi-finished product or end product has already done so. For the installer, office manager or HR manager who procures materials for their own use, practically nothing changes in that situation.
When it concerns your supplier, not yourself
There are situations where the passport is indeed relevant to your business operations, while you are not the party supplying it. Think of a foundry that purchases aluminium components from a manufacturer within the EU: responsibility for the passport then lies with that manufacturer, but the foundry may still be asked for it in its own chain by buyers further downstream. The same applies to a packaging company that takes aluminium foil and processes it into packaging; the question of whether the passport is complete and up to date can still come up during an audit or procurement process.
In such cases it is useful to know what data your supplier will have to be able to show, even if you do not compile the passport yourself. Those who want to check this for their own situation can see in a few questions whether this is relevant for your company without any obligation attached to it.
A company that both manufactures and uses
Some companies fall into two roles at once. A profile manufacturer that processes its own semi-finished materials into an end product is a supplier for one part of the process and a customer of its own material for the other part. In such cases, the distinction between "placing on the market" and "internal processing" is decisive, and that distinction is not always straightforward to draw in every business operation. The official text of the regulation and its associated definitions provide the basis for this; your own assessment of the precise situation belongs with a lawyer or with the competent supervisory authority.
For those who want to first sort out the concepts themselves, there is the knowledge base with concepts per situation, which explains, among other things, what falls under a supplier and what falls under aluminium as a product category.
Not everything is settled yet
The obligation for aluminium must still be worked out in a delegated act; according to the European Commission's work plan for 2025-2030, this is expected in 2027. Only after that will it become clear from which date the passport for aluminium will actually become mandatory, with an expectation around 2029 that is not yet fixed. As long as that act is not in place, no one can say with certainty which product categories within aluminium will be designated and which thresholds will apply.
Anyone wishing to understand how such a passport will be created and where the data comes from will find that overview on the page explaining where the information comes from. Frequently asked questions about the scope of the regulation, such as what happens if a company supplies both inside and outside the EU, are compiled on the page with frequently asked questions.
Are you still in doubt whether this applies to you?
Whether the digital product passport for your company will apply is usually easy to assess in a few minutes once you know what product you manufacture, import or only process. The free quick-scan provides an initial direction for this, and the knowledge bank helps you work out the concepts that play a role in your situation.