If you are wondering whether anything changes this year in the supervision of the aluminium product passport, the short answer is: the delegated act that sets out the precise rules for aluminium has not yet been published. This also means that it is not yet clear which authority in the Netherlands will specifically check whether a passport is present, up to date and correct. What is changing, however, is that the European Commission is implementing the work plan for 2025-2030 step by step, and each step makes the picture somewhat clearer.
For your company, this means above all: there is no enforcement practice yet to anticipate, but the direction is already set. The regulation itself is in force, the delegated act for aluminium is expected around 2027, and the passport itself will become practice around 2029. Supervision and enforcement will really come into focus only once that act is in place. Until then, it is mainly a matter of following what changes, not of anticipating a specific supervisory authority.
What is already established at this moment
The regulation on which the aluminium product passport will be based has a general structure for market surveillance: member states designate supervisory authorities that check whether products comply with the requirements, and those authorities are given powers to intervene if they do not. This structure already exists for other product groups and is not being reinvented for the product passport. What is not yet established is which Dutch authority will specifically be designated for aluminium semi-finished products, and what cooperation with supervisory authorities in other EU countries will look like in practice.
The time limits for enforcement are also not yet fixed. The regulation provides the framework, the delegated act fills this in per product group, and only then will clarity follow on how strict and how quickly checks will be carried out. Anyone now looking for a concrete date for a first inspection will not find one yet.
What is still open and why that is normal
It is a deliberate choice by the European legislator to first establish the general framework and only then, per product group, work out the details through delegated acts. Aluminium is one of the product groups included in the work plan 2025-2030, but it is not the first to be dealt with. This means that questions about fines, about the precise division of roles between supervisory authorities in different countries, and about what a check will look like in practice, cannot now be answered without speculation.
That is no reason to sit still. Preparation for the passport itself — which data you will have to provide later, who in your chain has which role, how your software fits in — can already begin, regardless of the question of who will be supervising later. Companies that use this period to get their data in order will be in a better position once enforcement becomes concrete than companies that wait for the first signs from a supervisory authority.
What this means for your company
For an installation company, an HR manager or an office manager reading this, the practical translation is simple: there is no new enforcement obligation this year for the aluminium product passport. What is changing are the intermediate steps in the European process, and these are mainly relevant for those who follow the development closely. Whether your company will later be under the supervision of a Dutch or another European authority depends on where you place aluminium on the market, not on where your company is established. search the knowledge bank for your situation provides an initial direction for this, sorted by topic.
It is wise to use this period also to examine how your own administration and software relate to what is coming. A passport is based on data that often already exists, but not always in the right place. With get an indication in a few questions of where you stand you quickly see whether your situation needs attention, without having to learn all about supervision first.
How to stay informed without having to follow everything yourself
Because the delegated act and the precise supervisory structure still have to appear, things will change regularly on this subject over the coming years. It is not necessary to monitor the European work plan yourself; that is precisely what we do. On how-it-works page you can read where our information comes from and how we keep track of what changes.
Would you like to know whether the aluminium product passport is already relevant for your business, and what you can reasonably prepare for now? Take the free quick-scan or read through the topics in the knowledge bank — both will give you an honest picture in half an hour, without having to become a lawyer yourself.