alupas.eu

Can I arrange the link to the aluminium product passport myself?

An overview of what you as a company can provide yourself for the aluminium product passport, and at which point the technical link usually lies outside your own capabilities.

Can I arrange the link to the aluminium product passport myself?

Partly yes, partly no. Gathering and providing the data that goes into the passport is usually something you can do well yourself: as no one else, you know which aluminium you purchase, from whom, and which certificates belong to it. The technical side — linking that data to a QR data carrier, generating a machine-readable file that meets the requirements of the regulation, and keeping it accessible for ten years — usually requires a specialized party in practice, simply because the technical standards are still very much in development.

The regulation itself does not prescribe who makes the link. It sets requirements for the result: the passport must exist, it must be accessible via a data carrier, and the data must be correct and remain current. How you organize that is up to you. That is precisely what the question "can I do this myself" comes down to in practice: not whether it is permitted, but whether it is feasible and sensible for your company.

What you can provide yourself

The basic data come from you, not from a software company. Think of the composition of the aluminium alloy, the origin, any recycled content, certificates from your supplier and data about processing. Providing that is administrative work: gathering data, checking it and putting it in a fixed structure. Companies that have their purchasing administration in order experience that as straightforward. Companies that have their supplier data scattered across email, paper and different systems notice that this part takes more time than expected.

To see which data are relevant for your specific situation, it helps to first look at the bigger picture in the knowledge base with topics per situation. There is an explanation per theme of what the regulation requires, without you immediately having to dive into the technical side.

Where the technology comes into play

Once the data are complete, something must be done with them: they must be converted into a format that machines can read, linked to a unique QR code, and hosted in a way that remains accessible for ten years — even if your company switches software suppliers or stops offering a product. That requires knowledge of the technical standards that the European Commission is still working out, and of the way in which supervisory authorities will assess those standards.

Building a system yourself that does this properly on an ongoing basis is not a realistic route for most SMEs: the standards are still changing, and an error in the technical setup affects not just one passport but all passports that have been set up that way. Many companies therefore choose a party that handles the technical side, while the substantive data are provided and checked by the company itself. How such a link looks in practice, and what information comes from where, is explained on the page how the data is processed into a passport.

The distinction between provider and service provider

The regulation places the responsibility for the accuracy of the data with the party that places the product on the market — usually the manufacturer or importer. That does not change because you outsource the technical implementation. A service provider that handles the link takes the technical work off your hands, not the responsibility for what is in the passport. That distinction is relevant for supervisory authorities: they look at who is responsible for the content, not only at who provided the technology.

It is therefore sensible to keep clear with each choice — do it yourself or outsource — who manages which part of the process. That prevents confusion when data need to be updated or checked.

When outsourcing is more sensible

If your company has limited IT capacity, no experience with data standards, or simply doesn't have the time to keep up with technical developments, outsourcing the technical part makes sense. This doesn't mean you lose control: you remain the owner of the data and determine what is submitted. A good first step is to look at where your company currently stands: what data you already have, and what part of the process is still missing.

With a few questions you immediately see an indication of what is relevant for your situation. If you have doubts about a specific part, you will find answers to frequently asked practical questions in the overview answers to questions that other companies also asked.

Do you want to know which part of the aluminium product passport you can realistically handle yourself and which part requires more than your current systems can provide? Take the free quick-scan or read through the topics in the knowledge base at your own pace to get a good picture before you make a choice.

This article is general information and not legal advice.