Short answer
Whether the digital product passport applies depends not only on the fact that your product contains aluminium, but also on the form in which that aluminium is placed on the market. The regulation is primarily aimed at aluminium as a semi-finished product: profiles, castings, plates and packaging aluminium that are traded as such. When such a semi-finished product is processed into a larger, composite product — a window frame, a machine part, packaging with other materials — the question shifts to who places which part of the product on the market and in what form.
This does not mean you can turn a blind eye once your product consists of multiple components. It means you must establish at which point in your chain the aluminium is supplied as an independent product, and at which point it is part of something else. These two situations can lead to different obligations, and the precise demarcation for aluminium has not yet been laid down in a delegated act.
Why composite products make the question more difficult
With a simple product — an aluminium profile sold directly to an installer — it is fairly straightforward who supplies the passport and which product it applies to. With a composite product, that is different. A casting that is built into a machine is an independent aluminium product at the time of casting. Once it is assembled into the machine, it is a component of another product with possibly its own rules.
The regulation distinguishes here between who places the product on the market and in which phase that happens. This can mean that the foundry supplying the loose component is responsible for the data on the aluminium itself, while the machine manufacturer is subject to different legislation for the end product — if applicable. For some product categories this process is further developed than for others; for aluminium as a material group, that process is still ongoing.
What is not yet fixed
The ESPR work plan 2025-2030 mentions aluminium as one of the categories for which a delegated act is being prepared, with expected publication in 2027. Only in that act will it be precisely laid down for which product forms of aluminium the passport becomes mandatory, and how aluminium that is already part of a larger composite product upon delivery will be handled. Until that text is available, no one can say with certainty how the boundary between semi-finished product and end product will be drawn.
What can be said is: supervisory authorities in such questions typically look at the moment when a product is actually placed on the market, and at who is responsible for that — the manufacturer, the importer, or another party in the chain. For a more detailed explanation of that division of roles, with examples per link in the chain, you can consult the knowledge base with the key concepts and roles .
What this means for your daily practice
Even without final rules, it is useful to map out now at which point in your own chain the aluminium is supplied as an independent product, and where it transitions into a composite end product. You will need that insight anyway, whether the obligation falls to you or to another party in the chain. Companies that supply profiles, castings or packaging aluminium to the next link in the chain are well advised to know now what data they can provide about their own semi-finished product, regardless of what happens with it later.
A quick way to see where your situation approximately stands is the product scan that provides a first indication in a few questions. That scan does not replace legal advice, but does help to determine which questions are relevant for your product. For questions that come up frequently at companies with composite products, there is also an overview with frequently asked questions about when the digital product passport applies.
Finally
The core is that aluminium in a composite product does not automatically fall outside or within the scope of the digital product passport — that depends on the phase in which it is placed on the market, and on legislation for aluminium that is not yet definitively established. For your own situation, especially if you are uncertain about who in the chain bears which responsibility, a lawyer or the competent supervisory authority remains the appropriate point of contact.
Do you want clarity on your own product and chain already? Then do the free quick-scan or read the other topics in the knowledge base. That way you know where you stand now, and what you can leave until the rules are definitive.