Who must supply the digital product passport for aluminium? The regulation provides a fairly precise answer to this, although it does not use the word "supplier". The market participant responsible is the one who places the aluminium product on the market of the European Union. In practice, this is usually the manufacturer, or — if that entity is established outside the EU — the importer who first places the product on the market within the EU.
For companies that only resell, such as a wholesaler, a profiles supplier or an installation company that purchases aluminium from an intermediary, the situation is different. In this type of regulation, they are usually referred to as a distributor, with a more limited role: they do not need to compile the passport themselves, but they do need to verify that it is present before they pass the product on. Which role applies to your company depends on what exactly you do with the aluminium: manufacture it yourself, import it from outside the EU, or only resell it within the EU.
What the regulation means by a market participant
The term market participant does not appear only in regulations on product passports. Similar role divisions have existed for some time in European product legislation, for example around CE marking. A distinction is made between the manufacturer, the importer, the authorised representative and the distributor. The regulation for the digital product passport builds on a similar classification, tailored to the question of who must make which product information available and who may verify that information before a product moves further along the chain.
The manufacturer: usually the first responsible party
Anyone who manufactures aluminium themselves or has it manufactured under their own name is generally considered a manufacturer. This party is the first to be responsible for providing the data needed for the passport: composition, origin of the material, and information relevant to recycling and reuse. This is also precisely the approach that alupas.eu works with: we compile the passport from the data supplied by the manufacturer or importer, and then host it for ten years.
When the importer takes on the role
If the manufacturer is established outside the European Union, responsibility shifts to the importer: the party that first places the product on the market within the EU. For companies that purchase aluminium profiles or semi-finished products from a manufacturer outside Europe, this is a distinction that really matters, because it determines who must have the passport drawn up and who is accountable for it. In the concepts looked up per situation this distinction is explained further, including the reference in the official text.
The authorised representative
A manufacturer outside the EU may also choose to appoint an authorised representative within the EU to carry out certain obligations on their behalf. This does not change who is ultimately responsible for the accuracy of the data, but it does change who in practice is the contact point for a supervisory authority or for a customer who has questions about the passport.
What is expected of a distributor
Companies that purchase and resell aluminium without processing it themselves or importing it from outside the EU generally fall under the role of distributor. They are not expected to compile their own passport, but they are expected to exercise a certain level of care: check whether the product already has a passport, and not simply disconnect it from the product during further sale. For many SMEs in the installation or trade sector, this is precisely the role they fall into, and it means significantly less is required of them compared to a manufacturer.
When this comes into play for your company
The obligation to provide a digital product passport for aluminium is being developed at EU level through a delegated act within the ecodesign regulation's work plan for 2025-2030. This act is currently expected in 2027, after which a separate entry into force date for aluminium will follow; based on the current work plan, around 2029 is expected. Both dates are not yet final and will be updated here as soon as the text is published. Those who wish to see now which role is likely to apply to their own business operations can do so in a few questions see which role applies to your business, entirely without obligation and free of charge.
What this article is not
This article describes how the regulation categorises roles, not how that categorisation will work out in detail for your specific business situation. In case of doubt about your own role, for example because a business both manufactures and imports, it is advisable to consult a lawyer or the competent supervisory authority. On how we collect the data for the passport you can also read where the information on alupas.eu comes from and how traceability is ensured in it.
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