When you read that a digital product passport is coming for aluminium, the first question is often: does that apply to everything we call aluminium, or only to certain forms? The short answer is that the regulation works with product categories within the material group aluminium, and the precise definition — which profiles, castings or packaging forms fall within it — is only fixed once the corresponding delegated act is published. Until then, 'aluminium' in the regulation is an umbrella term that is still being further defined.
What is clear: it is not about raw metal in the form of ingots or blocks, but about semi-finished products that have already undergone a processing step — extruded profiles, cast aluminium parts and aluminium packaging material such as foil, can stock and closures. This is also why the ESPR work plan mentions aluminium as a separate area of focus alongside textiles, furniture and other material streams: the EU wants to establish which data is relevant for each material group, and this differs by application.
Primary versus secondary aluminium: the detail that matters most
Within the discussion on the definition of aluminium, one distinction plays a larger role than others: the difference between primary aluminium (extracted from bauxite) and secondary aluminium (recycled from scrap or process waste). This distinction is not only chemical, it is also what the regulation looks at substantively. A product passport that must make circularity transparent has little value if it does not show what part of the material has already been through one life cycle.
For companies that produce or import profiles, castings or packaging aluminium, this means that the recycled content percentage will likely be one of the data points that must be included in the passport, along with origin and alloy composition. How that percentage is precisely determined and verified is not yet fixed. It is one of the elements where supervisory authorities and the European Commission still need to determine how strict and how detailed the requirements will be.
Alloy, coating and composite products
A second point that is often overlooked: aluminium is rarely applied in pure form. Profiles and castings are alloys, often with additions such as magnesium, silicon or copper, and packaging aluminium frequently has a coating or laminate. The question of whether such a composite product still qualifies as 'aluminium' in the sense of the regulation, or whether it is treated as a separate material, is precisely the type of question answered in the delegated act. For companies operating at the border between two material categories — for example aluminium with a plastic coating — this is a reason to continue to carefully follow the final text once it is published.
Because this definition is still under development, we recommend continuing to follow the official text on EUR-Lex for the precise wording, and in case of doubt about your own product group, consult a legal expert or the competent supervisory authority. We track developments and update the information on alupas.eu the knowledge base with explanations per situation as soon as something changes.
Why this is already relevant, even without a definitive date
The passport itself is expected around 2029, with a delegated act not anticipated before 2027 in turn. Yet it is useful to already know now within which product category your material will likely fall. Companies that extrude profiles, cast or process packaging aluminium are well advised to check what data on origin, alloy and recycled content are already available in their own production and procurement administration. That is precisely the type of data that will end up in the passport later, whatever exact form the definition takes.
If you would like a first impression of whether your products fall within the expected scope, then the quick-scan with a few short questions provides an indication based on the current state of the regulations. For those who want to know how the data that will be needed later are precisely built up, it is useful to read how we collect and process the data for the passport.
Finally
The term 'aluminium' in the regulation is therefore not a fixed, defined list, but a material group whose precise boundaries are still being drawn. For most SMEs in profiles, cast aluminium or packaging aluminium, the core is simple: the more you already know now about the origin and recycled content of your material, the less work it will be later to meet the requirements, whatever those requirements turn out to be exactly. If you are unsure whether your specific product falls within the expected scope, you will find more background in the frequently asked questions about the scope of the passport, or you do the free quick-scan to see where you stand now.