Can I arrange the QR data carrier for the aluminium product passport myself?
Generating a QR code is technically straightforward; you can do it with almost any free tool. The difficulty is not in making the code, but in what lies behind it: the code must point to the same, up-to-date and complete dataset for ten years, even if you change software suppliers, a product is modified or your company changes ownership.
Whether you can do this entirely yourself therefore does not depend on the question "can I make a QR code", but on the question "can I keep the underlying data available, correct and findable for ten years for anyone who asks for it". That second part is where most companies make a choice between managing it themselves and outsourcing.
What the data carrier must actually do
The QR code on or with an aluminium semi-finished product is nothing more than a reference. It does not contain data itself, but a link to a place where the data is located. When someone scans the code, they must arrive at a dataset that matches the product in their hand: alloy, origin, processing, safety information and the other fields prescribed by the regulation. What exactly must be in that dataset differs per product group and is not yet definitively fixed in all parts; the European Commission is working this out step by step through delegated acts.
This means that the data carrier and the data are actually two separate tasks. The code itself is a technical detail. The data behind it is an obligation that lasts ten years, even after bankruptcy, merger or discontinuation of a product line.
What you can reasonably do yourself
Creating and printing the QR code, determining where it goes on the product or packaging, and testing whether it scans properly under production conditions: these are tasks that are usually well-suited to a technical or quality team. Gathering the source data — composition, certificates, test results — also logically lies with you or your supplier, because no one else knows your product as well.
If your company already has a well-functioning quality management system and keeps data in a structured way, the step towards your own QR solution for part of the work is feasible. in a few questions see what this means for your situation gives a first indication of that.
Where doing it yourself becomes more complicated
The complications lie mainly in the duration and continuity. Ten years of hosting means: a server that keeps running, a domain that does not expire, a system that keeps pace with changes in the regulation, and a way to demonstrate which version of the data was online when. Companies that handle this internally must therefore not only build a technical solution, but also an organisational one: who is still responsible in 2032 if the original builder of the system no longer works for the company?
Moreover, the regulation itself makes a distinction between roles in the chain — manufacturer, importer, distributor — and obligations may differ per role. If you misjudge this, you run the risk that the data exists, but is not recorded in the right way or with the right party. worked out per situation which role fits you provides a starting point for that.
The conversation with your software supplier
If you do outsource part of it, it is useful to be clear beforehand about what exactly you are buying: only the technology of the QR code, or also the hosting, updates for legal changes and the guarantee that data can be found ten years back. Many companies only discover afterwards that a supplier provides the code, but does not guarantee long-term availability. how the data and the data carrier come together shows which components are involved.
What plays a role here
The date on which these obligations for aluminium actually come into force is not yet definitively fixed. On the basis of the Commission's current work plan, a delegated act is expected for 2027, with an expected practical entry into force around 2029. As soon as more information is available on this, it will be updated on alupas.eu. For your own situation — which role, which data, which deadline exactly applies — a lawyer or the competent supervisory authority remains the appropriate party to consult.
Would you first like to get an overview of what your business will entail before you decide between doing it yourself and outsourcing? The free quick-scan and the topics in the most frequently asked questions about the product passport provide an initial, cost-free overview.