Indicative adoption: 2027

The aluminium
digital product
passport

Aluminium is a priority intermediate product in the ESPR Working Plan, with adoption indicatively planned for 2027. Final product-specific passport requirements are not yet adopted.

What is known

An honest status report

The ESPR Working Plan lists aluminium as a priority intermediate product, with an indicative adoption year of 2027. That is a planning date, not an application deadline.

The final aluminium passport fields and granularity are not yet adopted.

Published work on steel can help frame preparation questions, but it is not a source of legal requirements for aluminium.

Why aluminium is grouped with steel

  • Intermediate, not final

    Sold on to be made into something else, like steel and unlike furniture.

  • Energy use

    Primary aluminium production uses substantial electricity. Energy and emissions records are useful data to review.

  • Recycled materials

    Recycling aluminium generally uses much less energy than primary production. Keep evidence for recycled-content claims; the final DPP fields remain to be set.

  • CBAM may already apply

    Certain aluminium goods fall within CBAM. Check the relevant commodity codes, importer obligations and exemptions rather than assuming every aluminium import is covered.

  • Cast and batch identity

    Like steel, aluminium has existing batch-level identity in casting and rolling records.

  • Downstream reach

    Construction, automotive and packaging all pull aluminium into their own regimes.

The adopted product-specific act will define the scope. ESPR Article 8(a) refers to product groups and CN codes where appropriate; it does not mean a final aluminium code list is already available.

Questions for preparation

What the steel study suggests

The steel study provides a comparison for preparation. Similarities between the industries do not establish aluminium passport requirements.

Element What to review now
Batch level Map existing cast, lot and batch records. The aluminium act will determine whether passports operate at model, batch or item level.
Existing certs Review inspection documents and certificates already issued for your products. Identify the fields that can be reused and the evidence behind them.
Carbon footprint Review existing emissions data and its boundaries. CBAM already includes specific embedded emissions for goods; a future DPP may use different methods or scope.
Recycled content Keep evidence for recycled-content claims and distinguish material categories where your records support it. No final aluminium DPP disclosure fields are adopted yet.
Three identifiers ESPR provides for product, operator and facility identifiers. Their required use depends on the regulation and applicable product-specific rules.

These are preparation topics, not an adopted aluminium passport specification.

What to do now

Three things that are safe to start

  • Review your emissions data

    Map data already used for CBAM, ETS or product assessments. Record the methodology and boundaries, then compare them with DPP requirements when those are adopted.

  • Document recycled-material evidence

    Link material claims to supplier records and chain-of-custody evidence where available. Avoid presenting an assumed future field as a legal requirement.

  • Check your batch records

    Identify cast and lot numbers in your records and check whether they can be linked to the relevant analysis and emissions data.

FAQ

See all questions

When will an aluminium Digital Product Passport be mandatory?

The application date is not fixed. The Working Plan indicates 2027 for adoption of aluminium rules. The final act will set its scope and application date.

What data will the aluminium passport contain?

The final product-specific fields are not yet adopted. Use preparation material to identify useful data, while keeping assumptions separate from confirmed requirements.

We already report under CBAM. Is that enough?

CBAM compliance does not automatically satisfy future DPP requirements. Existing embedded-emissions data may be useful, but the final DPP scope, methodology and information requirements must be checked separately.

Will every extrusion need its own passport?

That is not settled. The product-specific act will determine the required level. Map your existing model, batch and item identifiers so you can assess the eventual requirements.

Start with the data, not the act

DPPVIEW helps organise aluminium product records, supplier evidence and existing emissions information. Start with preparation while final product rules and our hosting platform are still in development.

Discuss passport preparation

sources

The sources explain the ESPR framework, CBAM and the steel preparatory study. The steel study is a comparison, not an aluminium legal specification.

Last reviewed: . This page describes a proposal, not adopted law. We update it when the Commission publishes a draft delegated act.