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How long does it take to draw up a digital product passport for aluminium?

The turnaround time depends mainly on how complete your own data and that of your suppliers already are — not on a fixed statutory deadline.

Short answer: it depends on your data, not on a fixed deadline

There is no statutory turnaround time in the regulation for how quickly a digital product passport must be ready once you start. What is fixed, however, is an expected start date for aluminium: this is expected around 2029, based on the ESPR roadmap 2025-2030, which mentions a delegated act for 2027. As long as that act has not been published, the exact date is not yet fixed.

In practice, it is not the law that determines the turnaround time, but the state of your own administration. Companies that already keep their material data, alloy composition and origin in a structured manner are often ready to compile a passport per product group within a few weeks. Companies where this data is scattered across multiple systems, suppliers or even on paper, should realistically plan for several months, especially if multiple product lines need to be tackled at the same time.

What determines the turnaround time in practice

Three factors keep coming back. First, the question of whether you yourself are the supplier within the meaning of the regulation, or whether that role lies with your sub-supplier — this determines who must supply the data and thus also who starts the clock. Second, the number of links in your chain: the more parties between raw material and end product, the more coordination is needed before all data is complete. Third, the extent to which your current software already provides structured data, or whether data must first be manually entered or requested.

Companies that do not know where they stand in advance often lose most time on figuring it out themselves, not on filling it in. A brief inventory beforehand therefore saves more time than they expect. With a few questions that will quickly give you insight you get an indication of where you are in that process, before you even speak to a supplier or service provider.

The steps in order

Broadly speaking, a company goes through four phases: collecting the source data on the aluminium and the production process, checking whether that data is complete and traceable, drawing up the passport itself, and linking it to a QR data carrier that remains accessible for ten years. The first two phases are most time-consuming in practice, because it must be established whether data from multiple suppliers fit together.

The last two phases are more technical in nature and proceed faster once the source data is in order. If you want to know where that data comes from exactly and how traceability is established, you can read that on the page explaining where the information comes from.

Where things get stuck in practice

The most common delay does not occur with the passport itself, but with the question of who in the chain is responsible for which piece of data. A profile manufacturer who purchases aluminium from a foundry must know which data the foundry already supplies and which he must add himself. If that agreement is missing, delays arise because data is requested back and forth without it being clear who has the final say.

A second bottleneck is the connection between existing software — ERP, quality systems, certificates — and the format in which a passport must be submitted. This is not so much a legal question as a technical one, and you should discuss it directly with your software supplier. A third bottleneck is internal: if no one has been explicitly assigned to lead the process, it will be left lying between daily operations.

What you can do now

Because the exact entry date is not yet fixed, there is no reason to hurry, but there is reason not to wait with the inventory. If you now map out which data are available and which are missing, you won't have to do that work all at once as soon as the obligation officially comes into force. An overview of the most frequently asked questions about timing and applicability can be found at the page with frequently asked questions.

For your own situation — who in your chain has which role and which data you specifically must provide — it is advisable to consult a lawyer or the competent supervisory authority. Alupas.eu compiles the product passport based on the data you and your suppliers provide, and hosts it for ten years.

Do you want to see without obligations where you stand now and which steps are relevant for your company? Do the free quick-scan or browse through the topics in the knowledge base with explanations per situation.

This article is general information and not legal advice.