Sectors and timing
Aluminium has no adopted EU passport rule
The Commission plans to adopt a rule in late 2027, so an aluminium passport applies in 2029 at the earliest. That year rests on a work plan.
No aluminium product needs a digital product passport today. The European Commission has adopted no rule for the group. On the Commission's own plan, the earliest date such a rule can apply is 2029.
Ignore that and one of two things happens to you. You buy a passport system against a rule that nobody has written. Or your European customer asks you for aluminium data next month, and you have no answer.
Nothing binds you today, because no rule exists
The Ecodesign for Sustainable Products Regulation (ESPR) creates the passport. It is Regulation (EU) 2024/1781, and it has been in force since 18 July 2024.
ESPR alone creates no passport duty for any product. Article 9 makes a passport a condition of market access, and only for a product group that a separate rule covers. That separate rule is a delegated act, and the Commission adopts one group at a time. See what is a delegated act.
As at 14 August 2026 the Commission has adopted no delegated act for any product group. Aluminium is one of the groups with nothing adopted. See which products need a passport, and when.
GS1 in Europe, a standards body, lists the priority product categories in ESPR Article 18(5). Aluminium sits on that list, beside iron and steel, textiles, furniture and tyres. A place on a priority list is not a rule.
The plan puts an aluminium delegated act in 2027, and marks it indicative
Read the status column first, because only the first row is law.
| Item | Status |
|---|---|
| ESPR, Regulation (EU) 2024/1781 | In force since 18 July 2024 |
| An aluminium delegated act | Not adopted |
| Commission adoption date for aluminium | Indicative, Q3 to Q4 2027 |
| The year beside aluminium in the MFAT report | 2027, an adoption year |
| Earliest date an aluminium passport can apply | 2029, calculated |
The Commission gives textiles, aluminium and tyres the same adoption date. It marks its own timeline as indicative.
The Ministry of Foreign Affairs and Trade (MFAT) published a market report in October 2025. It gives aluminium the year 2027. That is the year the Commission plans to adopt a rule, and it is not the year you must comply. See what New Zealand agencies have said.
The aluminium year rests on the working plan alone
Two other groups show public evidence behind their years, and aluminium shows none.
- Iron and steel: two Commission consultations closed on 12 August 2026.
- Textiles: a preparatory study runs, and its milestone on passport elements stays unpublished.
- Aluminium: no preparatory study milestone is published at all.
So the aluminium year carries less evidence than the steel year or the textile year. The Commission footnote on its textile page says implementation timelines may evolve as legislative and technical work progresses. The aluminium date can move in either direction.
Add the scrutiny period and the transition, and you get 2029
Read the table as arithmetic, not as a promise. Only the first row is a plan. The rows below it come from articles of ESPR that are in force.
| Step | Time | Source and status |
|---|---|---|
| The Commission adopts the delegated act | Q3 to Q4 2027 | Commission timeline, indicative |
| Parliament and Council may object | Two months, extendable by two more | ESPR Article 72(6), in force |
| The act enters into force | 20 days | Usual interval |
| Companies prepare | At least 18 months | ESPR Article 4(4), in force |
| An aluminium passport applies | 2029 at the earliest | Calculated |
Article 4(4) says the date of application "shall not be earlier than 18 months from its entry into force". The same article allows an earlier date in duly justified cases. So treat that period as the usual minimum, and not as a fixed period. How to read the timeline applies the same arithmetic to every group.
One passport duty binds sooner, and it does not come from ESPR. The battery regulation is Regulation (EU) 2023/1542. It covers three battery categories from 18 February 2027:
- each light means of transport (LMT) battery, such as an e-bike battery
- each industrial battery with a capacity greater than 2 kilowatt hours
- each electric vehicle battery
See batteries.
Nobody can tell you what data an aluminium passport will carry
No act exists, so no data fields exist. Any list of aluminium passport fields is a guess today, however confident the presentation. This site will name the fields when an act names them.
Four things around the data are settled, and they are worth knowing.
- The Commission cites six passport standards. The table below names them.
- Citation gives a product built to a standard a presumption of conformity. The standards stay voluntary. See the six standards.
- ESPR names the ISO/IEC 15459 series for the unique identifier and the data carrier. It does not name GS1 Digital Link. See identifier schemes: what is verified.
- The EU registry is operational, and no operator must upload to it yet.
| Standard | Subject |
|---|---|
| EN 18216 | Data exchange protocols |
| EN 18219 | Unique identifiers |
| EN 18220 | Data carriers |
| EN 18221 | Data storage, archiving, and persistence |
| EN 18222 | Application programming interfaces for product passport lifecycle management and searchability |
| EN 18223 | System interoperability |
Two numbers are missing from the set. There is no EN 18217 and no EN 18218. A source that writes the six as a range invents two standards.
The request reaches you as a purchase condition
This route reaches you before 2029, and no delegated act has to arrive first.
Aluminium usually goes inside somebody else's product. You may sell an extrusion to a window maker, a sheet to an appliance maker, or a casting to a machine builder. In each case your customer places the finished product on the EU market. Your customer thus carries any passport duty for that product.
Your customer can only state what you give them. So the customer turns the legal duty into a purchase condition, and that condition binds you by contract. The request arrives before any rule applies, because the customer wants the data before the first shipment. See if you supply a component.
A material passport and a finished product passport are different things
An aluminium passport would cover the metal, and a window that contains the metal would need a passport of its own. Nobody has written either act.
Warning: a vendor may answer the three questions below today. That answer is a product design decision, and it is not a legal requirement. Ask your customer what they want in the contract, and treat the legal question as open.
So this site cannot tell you how the two fit together. No checked source answers these three questions:
- Must a finished product passport carry the material data itself?
- May it point to a separate material passport instead?
- At which level does each passport sit: item, batch or model?
The duty falls on the operator that places the product on the EU market
ESPR Article 13(4) names the party:
The economic operator placing the product on the market or putting it into service shall upload, in the registry, the data referred to in paragraphs 1 and 2.
If you have no EU establishment, you are usually not that operator. Your EU importer or your EU customer is. See who is the economic operator.
That does not release you. The importer cannot publish data that you never sent it. The work still comes to you, and it comes in a purchase order.
Write the data duties into your purchase contract this year
- Do not buy an aluminium passport system this year. No rule defines the data.
- Monitor for the delegated act itself. Do not plan against an indicative year.
- Read the iron and steel act when the Commission adopts it. The plan puts it first. See iron and steel.
- Ask your EU customer which data they need, and when.
- Write the data duties into the purchase contract, field by field.
Do points 4 and 5 this year. See what this means for New Zealand exporters.