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What pieces do you need for the digital product passport for aluminium packaging?

An overview of the data required to compile the digital product passport for aluminium packaging, and why precision is particularly important for thin, mass-produced materials.

For the digital product passport for aluminium packaging you typically need four types of data: the material data of the alloy, the origin and share of recycled aluminium, data on coatings or paint layers that come into contact with food or liquid, and data about the manufacturer or importer responsible for placing it on the market. With packaging aluminium there is an additional detail that plays less of a role with profiles or castings: the thickness of the material is often so small that data on the alloy and the coating are directly linked to the question of whether the material may safely come into contact with food.

That detail determines in practice which pieces you collect and from whom. Foil, cans, caps and tubes are produced in large volumes and with varying batches, and a product passport compiled on the basis of outdated or incomplete data delivers little value. Therefore, completing this passport is not only a matter of providing data, but also of knowing which pieces your supplier already has and which you must request yourself.

The core: material, origin and composition

The basis of every aluminium product passport is the alloy designation, often recorded in a material certificate from the smelter or rolling mill. For packaging aluminium this certificate is usually linked to a specific batch or coil, because the properties of the alloy directly affect the formability into thin foil or sheet. In addition, the passport must include a statement of the share of recycled aluminium, broken down into pre- and post-consumer material insofar as that data is available from the supplier.

The detail that matters most in packaging

With packaging aluminium, the coating or paint layer is often the component that raises the most questions. A product passport records not only the aluminium alloy itself, but also whether a protective layer has been applied and what it is made of. For packaging that comes into contact with food or liquid, this information is relevant to the party taking delivery of the packaging, and therefore it is advisable to receive this information separately and completely from your supplier rather than as a general product description. This is precisely the point at which companies in the packaging sector more often get stuck than companies that supply profiles or castings: the data on the coating exists, but is often not in the same document as the alloy data.

Data about the manufacturer or importer

In addition to the material data, the passport must include the identity of the party responsible for placing it on the market: name, address and a registration number such as the Chamber of Commerce number. With packaging aluminium that is traded through multiple links in the chain, it is important to establish who in the chain fulfils this role, as this determines who supplies the data and who keeps it up to date. Read more about that division of roles in the knowledge base, where this has been worked out per situation.

What you can verify yourself

Whether your packaging aluminium falls within the scope of the future product passport and which pieces are relevant for your situation depends on the product and the way it is marketed. You get an initial indication by seeing in a few questions where your situation roughly stands. This is not a legal assessment, but a direction to work with.

How alupas.eu processes these pieces

We compile the passport based on the data you and your suppliers provide, and host the file for the agreed period. How that data reaches us and where it comes from is explained on the page where the information comes from. This way, you and your customers can trace which source data is based on which piece, which is especially important for packaging material with short production cycles.

No legal obligation yet, but a moment to gather

The delegated act that makes the digital product passport for aluminium mandatory is not yet published; the ESPR work plan mentions 2027 as the expected period, and the actual implementation date will be confirmed only once that act is in place. This does not mean there is nothing you can do: the documents mentioned above are documents you can request from your suppliers today, so you are not caught off guard once the date is confirmed. For questions about your own situation, or about how a supervisory authority will assess this, a lawyer or the competent supervisory authority is the appropriate contact; we compile the passport based on the data you provide, but we do not make statements about your individual obligations.

Would you like to know which of these documents for your packaging aluminium are already within reach and which are still missing? Take the free quick-scan or browse through the topics in the frequently asked questions, clearly organized by theme to see what is relevant for your situation.

This article is general information and not legal advice.