The short answer
The regulation that governs the digital product passport, the ESPR (Ecodesign for Sustainable Products Regulation), does not in principle tie in to the number of employees or turnover of your company. What matters is whether you place aluminium products within the designated category on the EU market, and what role you play in doing so: manufacturer, importer, authorised representative or distributor. A sole trader importing aluminium profiles from a country outside the EU can therefore be subject to the same obligations as a listed company doing the same.
This feels unfamiliar to many SME entrepreneurs, because other European regulations often do have a threshold for smaller companies. With the product passport, it works differently: the regulation is product-oriented, not company-size-oriented. Further down you will read why, and what that means in practice for whether it affects you.
Why the regulation does not look at company size
The aim of the ESPR is that data about a product are traceable and verifiable throughout its entire life cycle, regardless of who has made or imported the product. If smaller companies were exempted, part of the aluminium that reaches the European market would remain outside the scope of that control. This would undermine the aim of the regulation. For that reason, the emphasis is on the role in the supply chain and not on the size of the organisation fulfilling that role.
That does not detract from the fact that differences can indeed arise between companies, but those differences stem from something other than size: the question of whether aluminium is a stand-alone semi-finished product at your company that you place on the market yourself, or whether it is a component that has already been passported elsewhere in the supply chain. This question is covered in more detail in the explanation per situation in the knowledge base.
What the delegated act can still add
The ESPR is a framework regulation. The concrete rules for aluminium, including any special provisions for smaller market participants, still need to be laid down in a delegated act for this product group. This is foreseen in the European Commission's work plan 2025-2030, with an expectation around 2027 for publication. Whether exceptions or transitional periods for smaller companies will be included in it remains to be seen. Once that text is published, it can be found on EUR-Lex, and we will also update that supplement here.
What does matter, even if it is not about size
If company size is not a criterion, what is decisive then? In practice, it comes down to three questions. First: do you place the aluminium product on the European market yourself, or do you supply it to a party that does? Second: does the product fall within the category designated by the regulation, such as aluminium semi-finished products for profiles, castings or packaging? Third: what role do you play in this, since the obligations for a manufacturer differ from those for an importer or distributor.
These three questions determine in practice whether the passport applies to you, much more directly than the number of employees on your payroll. An office manager encountering this subject matter for the first time would therefore do well to first clarify their own role before looking at exactly what needs to be submitted. With a few questions you immediately see an indication of your situationwithout requiring an account.
Why this is nevertheless relevant for SME companies
Precisely because there is no lower limit for company size in the regulation, it is advisable for smaller companies not to assume that the rules apply only to large industrial players. An installation company that directly imports aluminium window frame profiles, a packaging company that purchases aluminium foil from a supplier outside the EU, or a small foundry that places components on the market under its own name: in each of these cases, the role in the chain determines whether the product passport is required, not the size of the enterprise.
That does not mean that every small company has to work everything out or prepare it itself. For many SMEs, it makes sense to have this conversation with their own software supplier or with the party that provides the data about the aluminium, and to consider how the data for the product passport are compiled and hosted. In this way, the question remains manageable, even without a legal background.
For your own situation
Whether the regulation applies to your company, and in what form, depends on the concrete role you perform and on the product category in which your aluminium falls. For an assessment of your specific situation, it is advisable to consult the official text or to contact a lawyer or the competent supervisory authority. General questions about the scope of the regulation are clearly organised on the page with answers to frequently asked questions.
Would you like to quickly and freely see where your company roughly stands? Do the quick-scan or browse through the knowledge bank; both are accessible without needing to log in.