Digital Product Passport for aluminium
The second intermediate product group, following the same logic as steel: get material passports in place so that finished-product passports have something credible to draw on.
Short answer. The aluminium delegated act is indicatively scheduled for 2027. Note that several secondary sources say 2028 — the working plan's own table says 2027, and the primary document is the one to trust.
What is in scope
Aluminium is listed as a priority intermediate product alongside iron and steel, with an indicative 2027 act. As with steel, it matters to most retailers indirectly: through the finished goods that contain it.
A source discrepancy worth knowing. A number of consultancy and vendor pages give aluminium an indicative date of 2028. The working plan COM(2025) 187 table gives 2027. Where secondary sources disagree with the primary document, use the primary document — and this is a good illustration of why it is worth checking.
Timeline for Aluminium
- 16 April 2025 Working plan names aluminium as a priority intermediate product, indicative act 2027.
- During 2027 Aluminium delegated act indicatively scheduled. Alongside textiles, tyres and the horizontal repairability act.
Data the passport has to carry
No delegated act exists for this group, so the product-specific field list does not yet exist. What is fixed is the ESPR framework's own Annex III data elements, which every passport must carry whatever the product. Those are listed below, together with the group-specific parameters the Commission has signalled.
Anything marked Expected is informed anticipation for data-collection planning, not a specification.
| Field | What it means in practice | Status |
|---|---|---|
| Unique product identifier | Persistent, connected to a data carrier on the product, its packaging or accompanying documentation. | In force |
| Unique operator identifiers | Manufacturer, other operators in the chain, and the EU-established responsible operator. Plus unique facility identifiers. | In force |
| Commodity codes | TARIC or equivalent, used at the customs verification step. | In force |
| Compliance documentation | Declaration of conformity, technical documentation, conformity certificates. | In force |
| Substances of concern | Name or code, location within the product, concentration or range, safe-use instructions and end-of-life handling. Framework-level under Article 7(5). | In force |
| Alloy designation | Against established alloy standards. Already well structured in industry data. | Expected |
| Embodied carbon | Primary aluminium is extremely energy-intensive; recycled aluminium is a fraction of that. This spread is the point of the exercise. | Expected |
| Recycled content | Share of secondary aluminium. The single most consequential circularity figure for this material. | Expected |
| Production route & energy source | Primary smelting versus remelting, and the electricity mix used — the dominant footprint variable. | Expected |
What this means if you sell aluminium products on PrestaShop
As with steel, this is a page to read rather than act on unless you sell semi-finished aluminium.
The one thing genuinely worth knowing: the carbon footprint difference between primary and recycled aluminium is very large. If you sell finished aluminium goods and make any environmental claim about them, that claim will become checkable when material passports exist — and Directive (EU) 2024/825, which bans generic environmental claims, applies from 27 September 2026, well before any aluminium passport.
The claims regime arrives first. Get the copy right before the data arrives to contradict it.
How to prepare now
Audit environmental claims on aluminium products
This has a firm date — 27 September 2026 — and is entirely within your control, unlike the passport.
Ask about recycled content
Suppliers of finished aluminium goods often can answer this, because their own material buyers track it. It is one of the easier passport-adjacent questions to get a real answer to.
Questions
Is aluminium 2027 or 2028?
Does this apply to aluminium packaging?
Sources
Other product groups
Batteries
The only product group with a binding passport date already set. LMT, EV and industrial batteries above 2 kWh, from 18 February 2027.
Textiles & apparel
First named priority under ESPR, and already subject to the unsold-goods destruction ban that took effect in July 2026.
Tyres
A priority group with an indicative 2027 act, and one that already carries mandatory EU labelling.
Get the data before you need the passport
Whatever your product group, the bottleneck is the same: supplier data you do not have yet. The readiness checklist tells you what to start asking for.