Whoever manufactures, imports or resells aluminium semi-finished products has a fixed role within the chain, and that role determines what the regulation expects from you. The Ecodesign Regulation (ESPR) works with a limited number of roles: manufacturer, authorised representative, importer and distributor. Each role has its own task in establishing and maintaining the digital product passport.
The manufacturer or producer is usually the party that provides the data on material, origin and composition, because that party actually manufactures the product. The importer who brings aluminium from outside the EU onto the European market acts as the first responsible party within the EU if the manufacturer is established outside the Union. The distributor, often a trading house or intermediary, resells without having to generate data themselves, but must be able to demonstrate that a passport is present.
The roles at a glance
The regulation refers to the "economic operator": anyone who places a product on the market, makes it available or uses it within a commercial activity. This includes four main roles. The manufacturer manufactures the aluminium product or has it manufactured and places it on the market under its own name. The authorised representative is a party within the EU designated on behalf of a manufacturer established outside the Union to fulfil certain obligations. The importer places products from outside the EU on the European market for the first time. The distributor, finally, makes the product available without being a manufacturer, authorised representative or importer.
One company can fulfil multiple roles at the same time. A profile manufacturer that also directly imports from an establishment outside the EU is simultaneously manufacturer and importer for that part of the production. That distinction is not just a label: it determines which data you must provide yourself and which you may take from a link earlier in the chain.
Why your role determines what you must provide
A distributor who purchases aluminium profiles from a certified supplier usually does not need to determine the material composition themselves: that information should already be in the passport that was supplied with the product. An importer who obtains aluminium casting or rolled products directly from a country outside the EU faces a different task, because in that case there may not yet be a passport and the importer is the first to bear responsibility within the EU for the accuracy of the data.
This distinction also relates to the question of who must keep which documents and who is accountable if a supervisory authority requests substantiation. How that submission works in practice depends on your position in the chain and the agreements you make with your own suppliers. In the knowledge base with explanations per role and situation you will find per role an explanation of what that means in practice.
The provider of the passport is not the same party as the responsible party
A common source of confusion is the difference between the economic operator responsible for the accuracy of the data, and the party that technically compiles the passport, hosts it and provides it with a QR data carrier. alupas.eu fulfils that latter, facilitating role: we compile the passport on the basis of the data provided by the manufacturer or importer, and host it for the retention period prescribed by the regulation. The substantive responsibility for the accuracy of that data remains with the economic operator, not with the party that hosts the passport.
This distinction is comparable to the relationship between a company and its accountant: the accountant processes and presents the figures, but the company remains responsible for their accuracy. Where exactly those data come from and how we handle them is explained on the page how the data in your passport are compiled.
What if you fulfil multiple roles at the same time?
Companies that both manufacture and import, or that also perform their own assembly as a distributor, are well advised to determine per product line which role applies at that moment. This is not a matter of preference, but follows from the actual activity: whoever manufactures the product or first places it on the market within the EU bears the heaviest obligations. A brief inventory of your own product flows will often already show where the question is most relevant.
To get a first impression of which role appears applicable to your company and what that entails, you can see in a few questions which role suits your situation. This provides an indication, not a legal opinion; for the exact qualification of your situation, the official text of the regulation or advice from a lawyer is the appropriate reference point.
Where you check this
The classification into manufacturer, authorised representative, importer and distributor is set out in the regulation itself, with the associated definitions. If you have doubts about your own position in the chain, this is a question that cannot be answered in general terms: the actual activities of your company are decisive, and the competent supervisory authority or a lawyer can assess these against your situation.
Would you like a broader picture before you take that step? Do the free quick-scan or read the other topics in the knowledge bank; both are a good starting point to see which questions are most relevant for your company.