What documents do you need for the digital product passport for aluminium?
For the digital product passport for aluminium, the same types of documents are generally collected: a material certificate with the alloy designation and chemical composition, a declaration of origin of the raw material, evidence of the recycling content, existing test certificates or safety information, and the identification details of the supplier placing the product on the market. Which documents are required and in what form is not yet settled: this will follow from the delegated act for aluminium, mentioned in the ESPR work plan 2025-2030 and currently expected in 2027.
What is already clear from the structure of the regulation: the passport builds on data that often already exists, only scattered across different departments and suppliers. For a profiles manufacturer, foundry or packaging producer, this means mainly locating and combining information, not creating it from scratch. Those who want to see which documents are relevant for their own situation will find this detailed by subject in the knowledge base.
Why recycling content is the most frequently requested detail
With aluminium, one point comes up clearly more often than with other materials: the evidence of recycling content. In practice, aluminium is often melted from a mix of scrap and primary metal, and this mix can differ per batch, per furnace and even per casting run. A profile or casting that comes off the line today therefore does not automatically contain the same percentage of recycled material as the previous delivery, even if it comes from the same smelter.
This makes the question 'which document shows the recycling content' more complicated than it sounds. A declaration from your direct supplier is usually not sufficient if that supplier themselves has no visibility of what the smelter used. In practice, the evidence must often be traced further back in the chain, to the party that actually melted or recycled the metal. When assessing such claims, supervisory authorities look at whether a percentage is demonstrable, not just whether it is stated.
Material certificate and composition
The material certificate, often a test certificate or mill certificate, contains the alloy designation and chemical composition. For most companies, this is the least problematic part: these certificates have existed for some time for quality assurance and are usually held by procurement or quality management. For the passport, this certificate is linked to the specific product, not to a general product line.
What if you don't have all the documents
At a small or medium-sized company that purchases and processes aluminium semi-finished products, part of the source documentation is often held by your own supplier or by an importer further down the chain. The regulation distinguishes between roles: whoever places the product on the European market for the first time bears a different responsibility than whoever only resells or processes it. Which role applies to your company, and what it means for document collection, can be determined most quickly with a few short questions about your situation.
Overlap with documentation that already exists
Some of the required information may already be in existing documents: a safety data sheet, a REACH registration, or a quality certificate according to a European standard. These documents are not the same as the product passport and do not replace it, but can serve as a source for parts of it. How such existing data are identified and processed into a passport is explained on the page about the working method.
What is not yet fixed
Because the delegated act for aluminium has not yet been published, the precise list of mandatory documents and the form in which they must be submitted is not yet fixed. As soon as that act is published, this article will be supplemented with the exact requirements. Until then, it is advisable to already have documentation on composition, origin and recycling content in order, especially since the last point often requires the most investigation.
For your own situation, including the question of what role your company has in the chain and which documents belong with it, a lawyer or the competent supervisory authority is the appropriate party. If you are unsure where you can already start, check the answers to the questions that other companies have already asked or do the free quick-scan to see in a few minutes which documents are relevant for your product.