For most companies, nothing concrete is changing in the obligation itself this year. The delegated act that sets out the requirements for aluminium has not yet been published; it is currently expected around 2027, with an entry into force date that follows. What can change are signals: an adjustment to the European Commission's work plan, a new consultation, an agenda for a working group. Those signals indicate a direction, but do not establish a date or obligation.
The distinction between the two is precisely what matters. An announcement, a draft text or a consultation is a step in a process. Only when a delegated act is definitively adopted and published in the Official Journal of the European Union does a concrete obligation with a date arise. Until then, news about aluminium and the product passport is an announcement of a process, not a law that you must already comply with.
What the Commission's work plan does and does not regulate
The Ecodesign for Sustainable Products Regulation operates with a work plan in which the Commission indicates for each period which product groups it wishes to prepare rules for. The current work plan runs from 2025 to 2030 and mentions aluminium as one of the groups for which work is being prepared. Such a work plan is an agenda, not a regulation. The work plan can be adjusted, a product group can be moved forward or backward, without that in itself creating an obligation for your company. Anyone reading the work plan as a timeline with fixed dates is reading more into it than is there.
Signals that indicate something, without establishing anything
There are a few places where you can pick up signals early. Stakeholder consultations, in which the Commission asks interested parties for input before drafting a text, show which issues are at stake: recycled content, origin, emissions in production. Meetings of the Ecodesign Forum, in which Member States and sector parties help shape the implementation, give an impression of which requirements are being considered. And once a draft delegated act appears for consultation before it is adopted, that is the clearest signal that an obligation is coming. However, none of these steps is the obligation itself.
What does not change, even with news
If a draft version of a text appears this year, that in itself does not change what is expected of your company. A draft can still be modified, withdrawn or remain on the shelf for years before it is adopted. Getting ahead of a draft is therefore not necessary; being aware of it is however advisable, so that you are not taken by surprise when the text becomes final. In the overview of topics per situation we keep track of which concepts and obligations have now been established and which are still being prepared, so that you can easily make that distinction.
Who is keeping an eye on this for you
Industry organisations typically monitor such developments closely, and for the legal significance of a concrete step, your own lawyer or the competent supervisory authority is the right party. What we do is maintain the official sources and indicate when something changes that is relevant for aluminium. In how we maintain the official sources you can read where that information comes from and how it reaches us, so that you can yourself verify whether something is an announcement or an established rule.
Making your own initial assessment yourself
Even though there is no final text yet, it can be useful to already know where your company stands approximately: which data you probably already have in-house, and which are still missing. This does not need to wait for the delegated act. With get a first indication in a few questions you can see where you stand now, without needing an account for that.
If you have another question about what is and is not established, check out answers to the questions that other entrepreneurs ask or take the free quick-scan to see which topics are relevant for your company.