Eco-design and digital product passport: what awaits those who manufacture in metal

Until now, sustainability in manufacturing has primarily been a selling point. That's changing: it's becoming a documented requirement, and that changes who is affected and when.

This article is a practical guide, not a legal analysis. If your product falls under any of these regulations, you should really consult with an advisor.

What's Underway

The European Ecodesign Regulation. It expands the logic of the old ecodesign—which only considered energy-consuming products—to virtually any product placed on the European market. It establishes requirements for durability, repairability, recycled content, resource efficiency, and information. It is not applied all at once: it is rolled out gradually by product groups, with specific actions for each.

The digital product passport. This is the element that will most significantly change daily operations. The idea: each product has an associated, accessible record detailing what it's made of, where it comes from, its environmental impact, and what can be done with it at the end of its life. For component manufacturers, this means that a customer will request this information contractually long before the law requires it directly.

The Border Adjustment Mechanism (BAM). affects imported iron, steel, and aluminium, among other things. The key issue here isn't the tax itself, but rather that it requires the declaration of embodied emissions, which pushes the data requirement further back along the entire supply chain.

Corporate Sustainability Reports. Large companies are required to report on their value chain. And the practical way that reaches a small shop floor isn't through an inspection: it's through their customer questionnaire.

How does this reach the person who prints metal?

It almost never comes in the form of a law that names you. It arrives like this:

A large client sends you a supplier questionnaire with questions about carbon footprint and materials.
A tender document includes a clause regarding recycled content or traceability of origin.
A client asks for the carbon footprint of the specific part, not of your company.
And the worst of all: you're left off a list of approved suppliers because you can't answer.

The pattern is always the same, and it's the same as with technical qualifications: the data must be recorded from the beginning, because reconstructing it later is impossible.

What should you start registering now

None of this requires an expensive system. It requires consistency.

Data	Why they'll ask for it
Origin and casting of each powder batch	This is the basis of everything else, and it's also necessary for qualification
Recycled content of the material	Appears on almost all new sheets
kWh per build and build plate utilization	This is what allows calculating a footprint per part that can be supported. It's in energy consumption
Powder reuse cycles and removal criteria	Demonstrates real material efficiency, not just brochure efficiency. It's in powder reuse
Destination of removed powder and substrates	The waste portion, which is what nobody documents
Part weight and equivalent gross weight	It is the comparison that strengthens the argument against mechanization

With that half-dozen columns on a sheet of paper, you can answer 90% of the questionnaires that arrive today.

Where additive manufacturing works in your favor

And it's best to say this without exaggerating, because exaggerating here is costly:

Manufacture only what is needed, when it is needed. This eliminates overproduction and inventory, which is the biggest and least measured inefficiency. It's reflected in the footprint of a spare part made nearby.**
Lighten parts that will move throughout their lifespan: the savings accumulate with every hour of use, not just during manufacturing.**
Extend the life of equipment by manufacturing the spare part that is no longer available.**
Repair instead of replacing, whenever technology allows.

And where it doesn't work in its favor: simple parts in long series, and anything that involves melting a lot of powder to throw half of it away on supports.

The recommendation

Don't wait for the questionnaire to arrive. Starting to record the six data points above at the next build site takes just a few minutes per job and, in two years' time, it's the difference between responding in an afternoon or being left out.

It's exactly the same lesson as technical traceability: it's almost free while it's being manufactured, and impossible afterwards.

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What it means to manufacture the equipment here instead of importing it, in an LPBF machine manufactured in Europe. The complete approach, in is 3D printing metal sustainable?. And the machines we're talking about, in ALBA 300 and ALBA 500.