If you are importing aluminium semi-finished products from outside the EU, you will generally need more documents than a company that purchases within the EU. In addition to the usual technical data on the material, these are documents that demonstrate who is responsible for the accuracy of that data: an agreement or power of attorney with the manufacturer outside the EU, proof of origin, customs documents and the technical documentation that the manufacturer would normally supply itself.
The reason is simple: the regulation targets whoever places the product on the EU market. If the manufacturer is outside the EU, that responsibility often shifts to the importer. This affects not only the amount of paperwork, but also the question of who may and must supply which data for the passport.
Why importing carries a different role
The regulation distinguishes between different parties in the chain: the manufacturer, the importer, the distributor and, as an overarching concept, the supplier that places the product on the market. As long as the manufacturer is within the EU, responsibility for the passport usually lies with that manufacturer. Once the aluminium comes from outside the EU, that responsibility often lies with the party that places the product on the EU market, and in many cases that is the importer.
This does not mean that the importer must invent all the technical data themselves. It does mean that the importer must be able to demonstrate that the data is correct and where it comes from. You can read more about that division of roles in the knowledge base with an explanation per role in the supply chain.
The list: what is usually requested
For imports of aluminium from outside the EU, the following documents are usually involved, in addition to the usual material data such as alloy, raw material origin and recycled content.
First, an agreement or power of attorney between the importer and the manufacturer outside the EU, stating who supplies which data and who is responsible for it. Second, documents that confirm origin, such as a declaration of origin or the underlying trade documents. Third, the customs documents that come with imports. Fourth, the technical documentation from the manufacturer itself: test reports, specifications and, where applicable, safety data sheets. Fifth, if there is an intermediary between the manufacturer and the importer, the documents showing how the aluminium reached you through that party.
Which specific documents are needed in a concrete situation depends on the product and the chain. A lawyer or the competent supervisory authority can assess this on a case-by-case basis.
The detail that matters most here: who signs off on the data
When importing from outside the EU, the point most often overlooked is not the amount of paperwork, but the question of who is formally responsible for the accuracy of the data in the passport. Within the EU, that responsibility usually clearly lies with the manufacturer, who generated the data themselves. When importing from outside the EU, an additional link is created: the importer receives data from a party that is not directly subject to EU oversight, and must themselves be able to substantiate that the data is correct.
That is precisely why an agreement or power of attorney with the manufacturer outside the EU is on the list, and not as a formality but as a key element. Without that document, it is not easy for a supervisory authority to determine who within the EU can be held accountable for the content of the passport. Supervisory authorities look, among other things, at the traceability of data to the source, not just at the presence of a passport in itself.
What this means for the passport itself
For the passport, this makes a difference in practice: the data included must be traceable to a source, and when importing from outside the EU, that source is one step further removed than when dealing with a manufacturer within the EU. This requires more careful collection beforehand, and clear agreements with the supplier about who provides and updates which data.
How the link between the supplied data and the final passport works is described on the page about how the information is compiled. There you can also see why the source of each piece of data remains visible, even after the passport is published.
How to approach this
It is advisable to gather these documents before you discuss the technical link with a software supplier or platform. With a complete file, that discussion will go faster, and you will prevent data from having to be requested later from a manufacturer located outside the EU who does not always respond quickly.
If you are unsure which documents are needed in your specific chain, it is best to submit this to a lawyer or the competent supervisory authority. A first indication of what applies to your situation can be obtained with the quick-scan that maps your situation in a few questions. Frequently asked questions about documentation and roles in the chain can be found compiled on the page with frequently asked questions.
If you want to read more broadly about what is required of you per situation, the free quick-scan is a good starting point, or view the topics in the knowledge base that are closest to your situation.