Check your DPP readiness

ALUMINIUM · ESPR PRIORITY PRODUCT GROUP

Digital Product Passports for Aluminium

Aluminium is prioritised under ESPR and the 2025–2030 Working Plan as an intermediate product group. The Commission currently indicates Q3–Q4 2027 for delegated-act adoption, not a company compliance deadline. The final scope, DPP requirements and application date remain open.

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Current position

Regulatory status at a glance

The ESPR framework is in place; the aluminium delegated act will determine any binding product-specific requirements.

Priority

ESPR priority product group

Aluminium is included in the first ESPR Working Plan 2025–2030.

Value chain

Intermediate material

Aluminium feeds downstream products. Future obligations will depend on which aluminium products the delegated act covers and each operator’s role.

Indicative timing

Q3–Q4 2027 adoption target

The Commission’s current roadmap indicates delegated-act adoption in Q3–Q4 2027. This is not a company compliance deadline.

Uncertainty

Requirements are not final

Covered products, ecodesign and passport details, and the application date are not yet defined.

Potential scope

Who may be affected

Aluminium is an intermediate material used in downstream products. These are likely value-chain roles, not the final legal scope; the covered products and specific duties, including for imports, depend on the aluminium delegated act.

Economic operators

  • Primary and secondary aluminium producers
  • Manufacturers of potentially covered semi-finished or intermediate aluminium products
  • Importers of potentially covered aluminium products
  • Downstream economic operators depending on upstream aluminium data

Regulatory sequence

Aluminium DPP timeline

An adoption target is not an application date. Sector-specific requirements and any transition periods remain pending.

  1. 2024

    ESPR establishes the framework

    Regulation (EU) 2024/1781 establishes the framework for product-specific ecodesign requirements and Digital Product Passports.

  2. April 2025

    Aluminium included in first Working Plan

    The 2025–2030 Working Plan prioritises aluminium.

  3. 2026

    Horizontal DPP infrastructure

    Horizontal standards and infrastructure develop, and the DPP Registry is operational; aluminium sector details remain pending.

  4. Q3–Q4 2027Indicative

    Aluminium delegated act planned

    This is the Commission’s indicative adoption period, not a company compliance or application deadline.

  5. Application dateNot yet defined

    Start depends on final delegated act

    No aluminium application date is defined yet.

Confirmed framework

What is already known about the DPP framework?

ESPR establishes the horizontal framework where a product-specific delegated act requires a DPP; it does not itself settle the aluminium dataset.

  • Unique product identity

    A passport is linked to a persistent unique product identifier. The exact identifier level for aluminium remains pending.

  • Physical data carrier

    A physical data carrier gives access to the passport. Its placement for aluminium remains pending.

  • Interoperable data

    DPP data uses open standards and interoperable formats and, where appropriate, is machine-readable, structured, searchable and transferable.

  • Reliable information

    Passport information must be accurate, complete and kept up to date.

  • Product-specific rules

    The aluminium delegated act will determine which ecodesign and information requirements, including any DPP fields, apply.

Pending delegated act

What is still to be defined for aluminium?

The aluminium delegated act will determine the binding product scope and requirements; those details are not yet defined.

  • Product scope

    Covered aluminium products, boundaries and exclusions are not final.

  • Required DPP data

    The final dataset, including whether any recycled-content or carbon-footprint information is required, is not defined.

  • Passport granularity

    Whether the passport applies at product, batch or individual-item level is pending.

  • Data-carrier placement

    Placement on a product, packaging or accompanying documentation is pending.

  • Access rights

    Public and restricted information and the actors entitled to access it remain pending.

  • Ecodesign requirements

    Any aluminium-specific performance or information requirements remain pending.

  • Not yet defined

    Application date

    The start of any product-specific obligations depends on the final delegated act.

Provisional only

Possible data categories to prepare for

These are provisional preparation areas, not a final or mandatory DPP field list. The delegated act will determine whether and how any category applies:

  1. 01Product identity and classification
  2. 02Alloy and material composition
  3. 03Recycled-content and circularity information where required
  4. 04Production-route and sustainability or environmental information
  5. 05Upstream evidence and traceability
  6. 06Compliance documentation

Readiness pathway

Five steps to start now

Organise existing information without assuming the final aluminium scope or dataset.

  1. Map product families and alloys

    List aluminium product families, alloys and commercial identifiers that may be relevant.

  2. Locate source data

    Find composition, production and sustainability records across source systems.

  3. Map upstream evidence

    Identify recycled-content information and supplier evidence available today, without treating it as a mandatory field.

  4. Assign data ownership

    Identify owners for plant, product and evidence data, review and updates.

  5. Structure identifiers and evidence

    Normalise structured identifiers and evidence links for possible future DPP publication.

Ease your transition with Circlepass

Want help working through this list? We can support your team step by step.

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How Circlepass helps

Turn aluminium data into workable DPP foundations

Circlepass helps teams connect product and supplier records, evidence, ownership and controlled update workflows. This supports readiness as requirements evolve; it is not a certification or compliance guarantee.

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Aluminium DPP questions

Is an aluminium DPP mandatory now?

No aluminium-specific DPP obligation is final at the review date. ESPR provides the framework; a future delegated act would define any covered products, obligations and timing.

Is 2027 the compliance deadline?

No. Q3–Q4 2027 is an indicative period for delegated-act adoption, not a compliance or application deadline. The application date is not yet defined.

Which aluminium products will be covered?

The final product scope is not yet defined. Aluminium is a priority intermediate product group, but the aluminium delegated act will determine which products are covered.

What about imported aluminium?

Covered products placed on the EU market may include imports. Specific obligations for importers and other operators depend on the final aluminium delegated act and their circumstances.

What product or material data might be relevant?

Identity, alloy composition, circularity, production, sustainability, upstream evidence and compliance records are useful preparation areas. No carbon-footprint or recycled-content field should be treated as mandatory for aluminium before the delegated act defines it.

What can producers do before the delegated act is final?

Map product families and alloys, locate source data, assess upstream evidence availability, assign owners and prepare identifiers and evidence links. These are readiness steps, not a claim about final legal requirements.

Official EU sources

Regulatory references last checked on 24 September 2026

  1. 01Ecodesign for Sustainable Products Regulation (EU) 2024/1781
  2. 02ESPR and Energy Labelling Working Plan 2025–2030
  3. 03JRC study on new product priorities under ESPR
  4. 04European Commission: Digital Product Passport overview
  5. 05European Commission: DPP Registry
  6. 06European Commission: DPP guidance for economic operators