For most companies that manufacture, import or process aluminium semi-finished products, little changes legally this year. The obligation to provide a digital product passport is not yet fixed. It depends on a delegated act that the European Commission must adopt for aluminium within the framework of the Ecodesign for Sustainable Products Regulation, or ESPR for short. That act does not yet exist.
What does change is the status of the process towards it. The Commission's work plan for the period 2025-2030 indicates when it expects to publish that delegated act, and that moment can be postponed as preparations progress. For aluminium, 2027 is currently mentioned as the year in which the delegated act is expected. The date on which companies actually have to start delivering is likely to be a few years later, around 2029. Both dates are explicitly not fixed and may change once the Commission takes further steps.
What a work plan is and is not
A work plan of the Commission is a planning document, not a law. It indicates which product groups are prioritised and in which order the Commission plans to prepare delegated acts. It is intended to give companies and supervisory authorities an indication, not to establish rights or obligations. Because of this, a work plan can be adjusted from year to year: one product group can move forward, another can be delayed, for example because a consultation takes more time than planned. Anyone wishing to monitor progress therefore reads not only the work plan itself, but also the announcements the Commission publishes afterwards. We explain how this structure fits together on the page on how our information is compiled.
What concretely happens this year, and what does not
As long as the delegated act for aluminium has not been published, there is no legal obligation to provide a digital product passport. What can happen this year is that the Commission circulates a draft version, consults industry organisations, or publishes an interim update of the work plan. These are signals about the direction, not obligations. For a company processing aluminium, this means above all that nothing needs to be submitted this year, but also that the preparation time becomes shorter as 2027 approaches.
Why not changing still means something
The direction of the regulation is not in question: an obligation will come, the question is when and in what exact form. Companies that now already map out which data about their aluminium is available, and where it comes from, will not have to catch up in a short time later. This is not legal advice to act now, but a practical observation: gathering data takes time, and that time is available now. If you want to know what such preparation looks like in practice, you will find a first indication via the quick-scan that shows in a few questions approximately where you stand.
What you can do, even without a fixed date
Even without a published delegated act, it is worthwhile to know which information will probably be requested: origin of the material, composition, recycling percentage and the parties in the chain responsible for these. This question recurs in almost every elaboration of the ESPR to date, also for other product groups. A good overview of what these concepts precisely mean, and how they will come together in a passport, can be found in the knowledge base with the topics that match your situation.
How to follow changes without having to search for them yourself
The work plan is not rewritten every year, but is adjusted whenever the Commission publishes new information. For companies that need to keep track of this alongside their regular work, that is difficult to follow: these are documents that are scattered across different EU sources. On alupas.eu we keep track of the work plan and the status of the delegated act for aluminium, and the location in the official text is freely available for everyone to consult, also without an account. Frequently asked questions about the planning and its meaning are collected on the page with frequently asked questions.
In brief
This year, little changes for most aluminium companies in terms of what is mandatory: there is no delegated act yet, so no supply obligation. What can shift is the planning itself, and that planning is worth following, precisely because the preparation time is finite. For your own situation, and for questions that go beyond the general state of affairs, consulting a lawyer or the competent supervisory authority remains the appropriate course of action.
Would you like to get an idea of where your company approximately stands, without any cost? The free quick scan provides a first indication in a few questions, and the knowledge base shows which topics are relevant for your situation.