What is a Digital Product Passport?
The transition toward a more sustainable and circular economy requires better access to reliable product information. A Digital Product Passport (DPP) is a structured, machine-readable digital record that connects a physical product with trusted data throughout its lifecycle - from raw materials and manufacturing to use, repair, reuse, and end-of-life.
Accessible through a digital carrier such as a QR code, RFID, or NFC tag, the DPP provides information about a product’s identity, composition, origin, sustainability characteristics, carbon footprint, and end-of-life handling.
Introduced under the Ecodesign for Sustainable Products Regulation (ESPR) (EU) 2024/1781, DPPs will become a key instrument for improving transparency, traceability, and circularity across European value chains.
Who is affected?
- Manufacturers and importers
- Distributors and retailers
- Repairers and recyclers
- Consumers and authorities
DPP requirements are being introduced gradually through sector-specific delegated acts. These acts define the products covered, sustainability requirements, required data, DPP format, and transition periods for industry compliance.
Why Aluminium?
Iron, steel, and aluminium are among the highest-emission material categories globally. Together, these metals represent a significant share of industrial CO₂ emissions, which is why they have been identified as priority materials under the EU’s ESPR Working Plan 2025–2030.
The Digital Product Passport (DPP) will provide the mechanism for collecting, verifying, and sharing sustainability data across these value chains. For aluminium producers, the DPP will act as a regulatory data carrier, enabling industries such as automotive, construction, packaging, and manufacturing to verify the environmental performance and traceability of the materials they purchase.
Improving transparency around aluminium production routes, recycled content, and carbon footprint will support the EU’s circular economy and decarbonisation objectives.
Expected Aluminium DPP Data Requirements
While the final requirements will be confirmed through the aluminium delegated act, expected data areas include:
- Unique product identifier
- Alloy grade and specification
- Recycled content (pre- and post-consumer)
- Embodied carbon per tonne
- Primary vs secondary production route
- Smelter origin and electricity mix
- Substances of concern
- Conformity documentation
Expected DPP Access Methods
DPP access is expected through digital carriers such as:
- QR codes on products or packaging
- Mill certificate resolvers
- GS1 Digital Link or sector-specific APIs
The aluminium DPP will also closely align with CBAM reporting, allowing companies to reuse verified embodied-emissions data where applicable.
Certain packaging-grade aluminium products may instead fall under the Packaging and Packaging Waste Regulation (PPWR) framework.
Aluminium DPP Timeline: What Happens Next?
The aluminium DPP requirements will be developed through an ESPR delegated act.
EU Digital Product Passport Registry: Preparing for Registration
The EU Digital Product Passport Registry is now operational, representing an important step toward establishing the European DPP ecosystem. The Registry will support product identification, registration, and interoperability between different DPP systems.
Companies should begin preparing their internal processes, product identifiers, and data structures to ensure readiness for future sector-specific requirements.
For battery passports, the new rules also clarify how companies will verify their identity and register their passports. In particular, the economic operator placing the battery on the EU market will need a Qualified Electronic Seal.
Recommended next steps include:
- Identify the legal entity responsible for registering and managing product passports.
- Begin preparation for obtaining required digital credentials where applicable.
- Continue mapping and preparing required product data, including information collected from suppliers.
- Ensure internal systems can maintain accurate and updated passport information throughout the product lifecycle.
📌 Read our full guidance: The EU DPP Registry Is Live: Guidance on What to Do Next
Digital Product Passport Identifiers
A DPP is accessed through a unique product identifier encoded in the data carrier. Choosing the right identifier early is important, as changing identification systems later can be complex.
Common identifier approaches include:
GS1 identifiers (GTIN, GIAI, SGTIN)
Widely adopted and suitable for many consumer and industrial products, with GS1 Digital Link enabling web-based access.
URN / URI identifiers
Useful for industrial products and intermediate materials where customised identification is needed.
Decentralized Identifiers (DIDs)
Suitable for high-value, multi-party products requiring trusted digital identity and verifiable credentials.
For metals such as steel coils or aluminium ingots, identifier approaches may include URN-based identifiers linked to mill certificates, while other products may use GS1-based solutions.
Key Implementation Steps
- Select the appropriate identifier approach.
- Define the identification level (model, batch, or individual product).
- Establish a stable resolver for accessing DPP information.
- Register identifiers through the relevant DPP registry when required.
- Add the digital carrier (e.g., QR code) to the product or documentation.
Expected DPP Data Categories for Metals
The exact data requirements will be confirmed through the sector-specific delegated acts. However, based on ESPR principles and current working plans, Digital Product Passports for metals such as iron, steel, and aluminium are expected to cover seven main data categories:
- Product Identification
- Material Composition
- Production Route
- Carbon Intensity
- Performance and Mechanical Properties
- End-of-Life and Recyclability
- Compliance and Verification
What Will the Aluminium Delegated Act Define?
The ESPR delegated act will translate the general DPP framework into specific requirements for aluminium products.
It will define:
- Scope of application – which aluminium products are covered and any exclusions.
- Performance requirements – sustainability and ecodesign criteria that products must meet.
- Information requirements – data that must be provided through documentation and the DPP.
- DPP specifications – required data fields, formats, and access rules.
- Conformity requirements – compliance procedures, verification, and documentation.
- Transition periods – timelines for companies to adapt and meet the requirements.
Although the final requirements will only be confirmed once the delegated act is adopted, companies can already prepare by improving product data management, traceability, and sustainability information processes.
Preparing Before the Delegated Acts Are Finalised
Companies do not need to wait for the final delegated acts to start preparing for future DPP requirements. The ESPR framework already provides clear direction on the importance of product data, traceability, sustainability information, and circularity.
Key preparation steps include:
- Reviewing existing product data and identifying gaps
- Mapping supply chains and data availability
- Improving material and sustainability data collection
- Preparing digital systems for DPP data management
- Engaging suppliers on data sharing and traceability
- Training teams on upcoming ecodesign and DPP requirements
7-Step Preparation Plan for Metals Producers
To prepare for future iron, steel, and aluminium DPP requirements, companies can start building the necessary capabilities today:
- Identify applicable product groups – Map product portfolios against expected ESPR categories.
- Review existing data – Assess available EPDs, CBAM reports, carbon footprints, and sustainability data.
- Create a unified data model – Prepare a single source of product information supporting DPP and reporting needs.
- Improve supplier data collection – Strengthen traceability and sustainability data from suppliers.
- Prepare verification processes – Define how product and carbon data will be validated.
- Pilot a DPP implementation – Test data collection, digital carriers, and registry integration on a selected product line.
- Establish internal governance – Assign responsibilities for DPP data quality, updates, and lifecycle management.
The introduction of Digital Product Passports represents a major step toward greater transparency, traceability, and circularity across European industries.
For aluminium producers, future DPP requirements will create a stronger focus on material origin, recycled content, production routes, and carbon transparency. Although the final requirements will be defined through the delegated act, companies can already prepare by strengthening data management, supply chain visibility, and digital infrastructure.
Early preparation will help organisations adapt smoothly to future ESPR requirements and turn DPP compliance into an opportunity for improved transparency, sustainability performance, and trust across the value chain.
