Digital product passport for aluminium: when does it apply?
As of · sourced from primary law · not legal advice · Auf Deutsch lesen
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This English version was prepared with AI from the German page. No native speaker or lawyer has read it. Found a mistake? Write to office@proofpass.eu.
The short answer
Not yet. Aluminium is an intermediate product in the working plan under the ESPR, Regulation (EU) 2024/1781, with 2027 as the provisional year of adoption of a delegated act. Only that act can require a passport (Art. 9(1)), applying as a rule no earlier than 18 months after entry into force (Art. 4(4)). On 11 November 2026 there was none.
Art. 4(4), 9(1) and 18(5)(b) ESPR
Legal basis: aluminium as an intermediate product
Article 18(5)(b) ESPR names aluminium as a priority. The working plan COM(2025) 187 sees potential in climate change, energy consumption, air, water, biodiversity, soil pollution and raw materials, and highlights secondary materials. The measures are to complement existing environmental and climate measures for aluminium.
As with steel, a rule for the intermediate product affects every final product made from it. The Commission is examining whether to set information requirements only or to include final products with a high aluminium content. That has not been decided. For comparison: product passport for iron and steel.
Timeline with status
| Step | Date | Status | Provision |
|---|---|---|---|
| ESPR in force | 18 July 2024 | binding | Art. 80 Regulation (EU) 2024/1781 |
| Commission’s digital product passport registry (deadline) | 19 July 2026 | binding | Art. 13(1) ESPR, Implementing Regulation (EU) 2026/1778 |
| Delegated act for aluminium | 2027 | indicative | COM(2025) 187 |
| Passport duty for aluminium | as a rule no earlier than 18 months after the act enters into force | planned | Art. 4(4) ESPR |
Which data is fixed
None yet. The act sets which data must go in, which data carrier applies and whether the passport is kept at model, batch or item level (Art. 9(2)). The selection comes from Annex III ESPR.
Because the plan stresses secondary materials, it makes sense to keep recycled content and origin per batch traceable today. That is preparation, not a duty. The basics are in the guide Digital product passport: deadlines and product groups.
What you can do today
- Record per batch where primary and secondary aluminium come from.
- Keep inspection certificates and compliance documents per batch, with versions.
- Ask your customers in construction, packaging and vehicle manufacturing which information they will expect.
- Give every product a permanent address that a later data carrier can carry.
- Follow the 2027 act in the deadline tracker.
How ProofPass helps
The product passport module gives every product a permanent address, a QR code and an archive of every document version. All industries at a glance: product passport by industry.
Further reading
- The product passport module: permanent address, QR code and documents per product
- The basics in the guide Digital product passport: deadlines and product groups
- Every date per product group in the deadline tracker
- All industries at a glance: product passport by industry
Frequently asked questions
Do final products made of aluminium need a passport?
That is open. The working plan COM(2025) 187 is examining whether to include final products with a high aluminium content. The delegated act will decide.
Is 2027 a compliance date?
No. 2027 is the provisional year of adoption. The duty as a rule starts no earlier than 18 months after the act enters into force (Art. 4(4) ESPR).
Who uploads the identifiers to the registry?
The economic operator placing the product on the market or putting it into service (Art. 13(4) ESPR). The registry stores at least the unique identifiers; the delegated act may specify further data for it (Art. 13(1) and (2)).
With ProofPass
ProofPass does not provide a product passport under an ESPR act today, because there is none yet for this group. You get a permanent address per product, a QR code, a GS1 Digital Link address from your GTIN if you want one, and an archive of every document version. That is the groundwork a later passport needs. Which fields it requires is decided by the act alone.
The terms and legal notices are in German, and the German version is binding.
Sources
- Regulation (EU) 2024/1781 (Ecodesign for Sustainable Products Regulation, ESPR), Official Journal (read on 11 November 2026)
- European Commission: Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025-2030, COM(2025) 187 of 16 April 2025 (read on 11 November 2026)
- Implementing Regulation (EU) 2026/1778 (digital product passport registry), OJ of 17 July 2026
As of 11 November 2026. The legal text in force prevails. This page is not legal advice; sources are given above.