DPP for aluminium: why the most recyclable metal is among the first with a digital passport

Kiril ShivachevKiril ShivachevJuly 28, 20266 min read
CNC machining of an aluminium block, illustrating DPP requirements for tracing the carbon footprint of aluminium

Aluminium is everywhere, yet we almost never see it as it really is. It is the window frame, the beer can, the laptop lid, the car wheel, the aircraft body. Light, strong, endlessly recyclable — and at the same time one of the most energy-intensive materials humanity produces. That very combination puts it on the European Union's list for a Digital Product Passport.

After iron and steel, aluminium is the next base metal the EU will require to carry a passport. If you produce, process, import or use aluminium, this article explains what is coming, when, and why it is worth starting to prepare now.

Why aluminium is on the list

The answer lies in a paradox. Aluminium is the material of the circular economy — it can be recycled endlessly without losing quality, and recycling saves around 95% of the energy compared with production from raw material. And at the same time its primary production is brutally energy-hungry.

Primary aluminium is extracted through electrolysis, which devours enormous amounts of electricity. That is why the carbon footprint of one tonne varies dramatically depending on where the power comes from: from around 4 tonnes of CO₂ per tonne when produced with hydropower, to over 15–20 tonnes when powered by coal. The same metal, but with a radically different environmental profile depending on its origin.

This is why the EU wants transparency. Without data on origin and energy, “green aluminium” and “dirty aluminium” look identical on the market. The passport makes the difference visible.

When it takes effect

Aluminium is among the priority product groups in the first working plan under the Ecodesign Regulation (ESPR), adopted in April 2025. It travels in one package with textiles and tyres.

On the Commission's timeline, the delegated act setting the exact requirements for aluminium is expected in the second half of 2027. Its adoption is followed by the usual transition period of at least 18 months, which means a real obligation around 2029.

That sounds far off. It is not — and here is why: much of the data the passport will require is not yours. It sits with the bauxite supplier, the smelter, the electricity provider. Collecting it along the chain is a negotiation, not a software project, and it takes years, not weeks. The full picture of the timelines is in the working plan 2025–2030 and in the overview of the industries affected first.

What the passport of one tonne of aluminium will contain

The exact fields will be set by the delegated act, but the direction is clear from the steel requirements and from the logic of the material. Expect the passport to include:

Notice what all these fields have in common: they are data that today is either not collected systematically or lives scattered between departments and suppliers. The passport does not create new information — it requires you to organise it.

The CBAM link: one transparency, two requirements

Here is the most practical news for business. Aluminium is among the sectors covered by the Carbon Border Adjustment Mechanism (CBAM) — the EU's carbon levy on imports, whose definitive regime applies from 2026.

Both CBAM and DPP essentially want the same thing: reliable data on the carbon footprint of every tonne. CBAM wants it to calculate the levy on imports; DPP wants it to document the footprint transparently for the whole market.

A company that has already built its data for the DPP holds exactly what it needs for its CBAM declarations too. Transparency pays off twice, instead of being a double cost.

The reverse is also true: whoever is already wrestling with CBAM reporting is halfway to DPP. The two requirements are not separate bureaucratic burdens — they are two applications of the same data system.

What this means for your business

Europe has a real aluminium processing sector — rolled and extruded products, foil, construction profiles, automotive components. For these companies DPP is not an abstract Brussels topic, but a concrete future requirement from their own customers.

For manufacturers and processors

Start measuring and documenting the carbon footprint and recycled content now. Build a system for collecting data upstream — from the metal supplier to the energy contract. Whoever has this data first turns it into a competitive advantage rather than a last-minute scramble. See what DPP for manufacturers looks like.

For importers

If you import aluminium or products made from it, you will carry responsibility for the passport at the border — exactly as you carry responsibility for the carbon levy under CBAM. The conversation with the non-EU supplier about data must begin at the negotiation stage. More in DPP for importers.

For distributors and retailers

You will need to be able to pass the passport data down to your customers. Proof of registration will become a standard requirement when accepting goods — see DPP for retailers and service centres.

Aluminium as an advantage, not a burden

There is an angle that is often missed. Aluminium is one of the few materials where sustainability is not a trade-off with quality — recycled aluminium is practically indistinguishable from primary. That means that for manufacturers DPP can be not a burden, but a sales story.

A brand that can prove low-carbon, high-recycled aluminium with a passport in hand has a tangible advantage over a competitor who merely claims the same. In a world that increasingly wants proof instead of promises, that is the difference between a won and a lost contract. We unpacked this logic in B2B sales and DPP and in Made in Bulgaria and DPP.

Where to start

The obligation is around 2029, but preparation starts now — because the data is the slow part.

If you want to see how it works in practice, take a look at our product or book a call.


DPP for aluminium

Frequently asked questions

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Aluminium combines two factors that make it a priority: its primary production is extremely carbon-intensive (from around 4 to over 15 tonnes of CO₂ per tonne depending on the energy source), while at the same time it is endlessly recyclable, with recycling saving around 95% of the energy. The EU wants transparency to make the difference between low-carbon and high-carbon metal visible.

According to the ESPR working plan of April 2025, aluminium is a priority group alongside textiles and tyres. The delegated act with the exact requirements is expected in the second half of 2027, and the obligation itself after a transition period of at least 18 months — that is, around 2029.

It is expected to include the production route (primary via electrolysis or secondary from recycled metal), the verified carbon footprint per tonne with the energy source stated, the recycled-content percentage, the alloy and grade, mechanical properties, restricted substances and recycling instructions.

Aluminium is among the sectors covered by CBAM — the EU's carbon levy on imports. Both CBAM and DPP require reliable data on the carbon footprint of every tonne. A company that has built its data for one already holds what it needs for the other, so transparency pays off twice.

Start measuring and documenting the carbon footprint and recycled content, link DPP and CBAM reporting into one process, and talk to suppliers about origin and energy data. The data is the slow part of preparation and is gathered upstream, so an early start turns the requirement into a competitive advantage.

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