Yes, you can in principle collect and submit the data for the digital product passport for aluminium yourself. The regulation does not require this to be done by an external party; anyone who submits the data correctly, completely and in a traceable manner may do so themselves. What matters is not who enters the data, but whether the passport meets the requirements that will apply to aluminium: correct content, a fixed location via a QR code, and availability for the prescribed retention period.
For a clear range with a limited number of alloys and fixed suppliers, doing it yourself is feasible for many companies, provided the origin of each piece of data remains demonstrable and up-to-date. With a broader or changing range, multiple sub-suppliers, or when the technical formatting of the data carrier becomes more complex, companies more often choose to outsource this process to a party that handles storage and coupling with the QR code. What works for your company depends on the size of your product portfolio and the time and knowledge you have available internally to maintain it.
What the regulation requires, regardless of who carries it out
The European ecodesign regulation stipulates that products must soon have a digital passport with data on composition, origin and recyclability, accessible via a QR code, and that this data must remain accessible for a fixed period. For aluminium, the specific delegated act still needs to be published; according to the current work plan it is expected in 2027, after which the obligation for aluminium is expected to take effect around 2029. This date is therefore not yet fixed. What is clear is that the regulation describes which data must be included and how long it must remain accessible, but not who must build the technology behind it. If you first want to understand how such a passport is technically created, it helps to read how that data from source file to QR code are compiled.
What doing it yourself means in practice
If you handle it yourself, there is more to it than filling out a form. You must record the composition and origin of the aluminium, link that data to a fixed data carrier, set up a system that keeps that information accessible for the prescribed period, and maintain that system as your own IT environment changes. If the composition of a batch changes, that change must be traceable in the passport that belongs to that specific product. This requires not only knowledge of the material, but also a fixed, repeatable way of recording.
Where doing it yourself often fails
Most companies do not fail at collecting the data itself; that knowledge is usually already there, in procurement or quality assurance. Where it more often goes wrong is the continuity of hosting. A period of ten years is long: staff changes, systems are replaced, companies merge or close down. A passport that is no longer accessible after a system changeover does not meet the requirement of accessibility, no matter how carefully the data was entered. The technical formatting of the data carrier can also change once the delegated act for aluminium is finally published, which means a self-built system must be able to adapt to it. Practical questions about this, and the answers that already exist, are bundled in the most frequently asked questions about the passport.
Outsourcing solves the technology, not the responsibility
If you outsource the preparation and hosting, you transfer the practical work: the formatting, the linking with the QR code, and keeping the data accessible for the prescribed period. The responsibility for the accuracy of the source data, what is actually in the aluminium and where it comes from, remains in practice with the party that places the product on the market. Outsourcing thus changes who technically manages the passport, not who is responsible for its content. Which party in the chain has exactly which role differs per situation and is detailed in the knowledge base with explanations per subject.
Do it yourself and still maintain oversight
Whether doing it yourself for your company is realistic depends strongly on how many different products and alloys you carry, and on how your data is already recorded. Companies that handle it internally usually do so with a fixed responsible person, a fixed format for source data, and a periodic check on whether the data is still correct. Companies that outsource still retain the obligation to be able to substantiate the supplied data to the supervisory authority or customer.
For your own situation, this is not a choice you make on the basis of one article; consult the official text of the regulation or a lawyer if in doubt. Would you first like an indication of whether your situation is straightforward enough to handle yourself, or whether outsourcing is more appropriate? Take the free quick-scan and see in a few questions where you approximately stand.