The short answer: the technical requirements for the digital product passport itself are the same throughout the European Union, because the underlying legislation is a regulation and not a directive. What can differ between Member States is who carries out supervision, in which language accompanying information must be available, and how the practice proceeds when aluminium is imported from outside the EU.
This distinction is not unimportant for a company trading across borders. A regulation such as the ESPR (the Ecodesign Regulation under which the aluminium passport falls) applies directly: Member States do not need to first convert the text into their own national legislation, as must be done with a European directive. This means that the requirements for the passport, the data that must be included in it and the QR data carrier are identical on paper in every EU country. The implementation around it is a different matter.
What remains the same: the technical requirements for the passport
Because it is one regulation that applies directly throughout the Union, a manufacturer or importer in Germany, Poland or the Netherlands can rely on the same basis: which data are mandatory, how long the passport must remain available and what type of data carrier is used. This is precisely why a platform like this can compile passports without having to devise a different structure for each country. In the knowledge base by topic this distinction between the regulation itself and national implementation is explained further.
What differs: supervision and enforcement per Member State
A regulation sets the standard, but leaves supervision of compliance to the Member States themselves. Each EU country appoints its own market surveillance authority that checks whether products on the market meet the requirements. Which authority this is exactly, and how actively it carries out controls, differs per country and is published by the relevant authority itself. For the Dutch situation, the competent market surveillance authority is the designated route to ascertain who is responsible for what and how an inspection works in practice; this is not an assessment that can be made here.
What differs: language and practical accessibility
The data in the passport itself are structured and largely language-independent, but accompanying documentation, instructions for use or contact details that are provided with a product must generally align with the language of the country where the product is sold. Incidentally, this is nothing new under the ESPR: the same logic has already applied for some time to, for example, safety information for other product groups. A company that supplies aluminium semi-finished products in multiple countries should therefore check what additional language requirements apply in the country of destination, separately from the content of the passport itself.
What differs: imports from outside the EU
For aluminium imported from outside the European Union, there is an additional layer: customs at the external border of the Union. How strictly it is checked there whether a product already has a valid passport, and what documents are required for this, can vary per point of entry and per moment, simply because customs practice never proceeds identically everywhere. This particularly affects importers who source aluminium from outside the EU and subsequently place it on the European market for the first time; they are treated in the regulation as a separate role with its own obligations.
What this means for a company selling across borders
For a company that only supplies within the Netherlands, this topic remains largely theoretical. Once aluminium products cross the border, it becomes relevant to know that the content of the passport is the same everywhere, but supervision, language requirements and customs practice can differ per country. Anyone who wants to see which questions apply to their own situation can do that most quickly with a few questions that provide an immediate indication. For questions that come up frequently, there is an overview with answers to frequently asked questions, and anyone who wants to know where the information on this platform comes from exactly, can read that on the page about how the data is collected and checked.
This explanation is of a general nature and does not replace legal advice. For the exact explanation of the regulation, the official text on EUR-Lex always applies, and for the situation of a specific company, the competent supervisory authority or a lawyer is the appropriate point of contact. If you first want to get an idea of where your company stands, the free quick-scan is a logical starting point.