Critical Raw Materials Act: Permanent-Magnet Data Carriers and Passport Reuse
Article 28 CRMA creates permanent-magnet label and data-carrier duties. See the corrected implementing deadline, required data and DPP reuse rule.
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The Critical Raw Materials Act already creates a future product label and data-carrier architecture for permanent magnets, but the implementation clock cannot safely be converted into a calendar date yet. Article 28 of Regulation (EU) 2024/1252 says the label and carrier duties start two years after the relevant implementing act enters into force.
- Regulation (EU) 2024/1252 Article 28. The operational label and carrier trigger is an implementing measure that is still pending.
- The corrected implementing-act deadline is 24 November 2025. The original Official Journal text said 2026; Corrigendum 2024/90330 changed it.
- Label and carrier duties start two years after that implementing act enters into force, so there is no calendar date yet.
- Article 28 applies to MRI devices, motor vehicles and category-L light means of transport from 24 May 2029.
- Where another Union act requires a product passport, Article 28(4) magnet information goes into that passport.
A 3 June 2024 corrigendum changed the Article 28(2) deadline for that implementing act from 24 November 2026 to 24 November 2025. That corrected deadline has passed. No adopted Article 28(2) implementing act was identified in the primary-source search used for this page as at 3 September 2026, so the two-year trigger cannot yet be calculated. What is settled is the product scope, core magnet information and a rule that reuses another EU product passport where one is required.
Legal status
| Question | Current answer |
|---|---|
| Instrument | Regulation (EU) 2024/1252, Article 28 |
| Status | IMPLEMENTING MEASURE PENDING for the operational label/carrier trigger |
| Corrected implementing-act deadline | 24 November 2025 |
| Why some copies say 2026 | The original OJ text says 24 November 2026; Corrigendum 2024/90330 changes Article 28(2) to 24 November 2025 |
| Label and carrier application | Two years after the Article 28(2) implementing act enters into force |
| Special timing | Article 28 applies to MRI devices, motor vehicles and category-L light means of transport from 24 May 2029 |
| DPP reuse | If another Union act requires a product passport, Article 28(4) magnet information goes into that passport |
Primary law: Regulation (EU) 2024/1252. Correction: Corrigendum 2024/90330.
The date correction is not cosmetic
The original Official Journal rendering of Article 28(2) says the Commission shall adopt the implementing act by 24 November 2026. The official corrigendum published on 3 June 2024 changes that date to 24 November 2025.
A current article can't repeat the 2026 date simply because it appears in the uncorrected base text. The consolidated EUR-Lex text carries the correction.
The corrected statutory deadline has passed. Until the implementing act is identified and its entry-into-force date is known, the “two years after” trigger for the main Article 28 label and carrier duties is not established as a calendar date.
The EU Product Regulation Action Radar is designed to make this kind of situation visible.
Which products are named?
Article 28(1) names a defined set of products, including:
- magnetic resonance imaging devices;
- wind energy generators;
- industrial robots;
- motor vehicles;
- light means of transport;
- cooling generators;
- heat pumps;
- electric motors, including when integrated into other products;
- automatic washing machines;
- tumble dryers;
- microwaves;
- vacuum cleaners;
- dishwashers.
The label indicates whether the product incorporates permanent magnets and, where it does, whether they are neodymium-iron-boron, samarium-cobalt, aluminium-nickel-cobalt or ferrite.
Products primarily designed for defence or space applications are exempt, and Article 28 also contains specific vehicle exceptions and a mechanism for sector-specific Union harmonisation legislation to displace the Article 28 requirements for the products concerned.
What the data carrier must reach
For products within Article 28(3), the carrier is linked to a unique product identifier and gives access to information including:
- identity and contact information for the responsible person;
- weight, location and chemical composition of each permanent magnet;
- presence and type of coatings, glues and additives;
- information needed for access and safe removal, including removal sequence and required tools or technologies.
Where the permanent magnets are exclusively contained in one or more electric motors, Article 28 allows defined substitutions using motor location and motor-removal information.
The information must be complete, up to date and accurate and remain available for at least the product's typical lifetime plus ten years. It can be model-level or, where the information differs, batch- or unit-level. Repairers, recyclers, market-surveillance authorities and customs authorities are expressly named as users.
This is not a marketing microsite. It is regulated lifecycle information.
The passport-reuse rule is the important architecture point
Article 28(6) says that where a product covered by the magnet data-carrier rule is also required to have a product passport under another Union legal act, the Article 28(4) magnet information is to be included in that product passport.
That's not a second “magnet passport”.
For a product already inside a DPP regime, the design principle is:
one legal product record can carry an additional regulated information domain when the law explicitly requires reuse.
That makes Barcodes and Product Identifiers: What You Need and Which System Should Own Each Product Fact? relevant: the physical carrier, unique identifier and source system shouldn't be designed independently.
How the vehicle DCVP changes the permanent-magnet context
Regulation (EU) 2026/1738 brings permanent-magnet and e-drive-motor circularity information into the vehicle information architecture. Article 11 and Annex VI cover relevant removal, replacement and circularity information, and Article 13 later makes Article 11 information one of the DCVP's mandatory content territories.
That interacts with the Critical Raw Materials Act, but it's not a licence to say the DCVP simply swallows every CRMA Article 28 duty. The CRMA has its own passport-reuse and sector-harmonisation rules, including Article 28(8), while the final technical DCVP implementation is still pending.
Treat the systems as designed to align where the law allows it, while preserving the legal owner of each requirement. For Article 28(2) timing, use the current consolidated CRMA text and corrigendum rather than the stale uncorrected date.
For the vehicle-level passport, see EU Digital Circularity Vehicle Passport (DCVP): What Changes for Cars and Vans from 2032?
What businesses should do
| Action | What it means in practice |
|---|---|
| DO NOW | Identify whether any product family is one of the Article 28(1) product types and whether it contains one of the named permanent-magnet types. |
| DO NOW | Start sourcing magnet weight, location, composition, coatings/glues/additives and safe-removal information from engineering and suppliers. |
| PREPARE | Keep the data at model, batch or unit level according to where it varies. |
| PREPARE | Design the product identifier/carrier architecture so Article 28 data can be reused inside another Union product passport where required. |
| WATCH | Adoption and entry into force of the Article 28(2) implementing act and any sector-specific legislation that displaces the rule. |
| DO NOT HARD-CODE | A compliance date calculated from the corrected 24 November 2025 deadline. The trigger is the implementing act's entry into force, not its statutory due date. |
| DO NOT HARD-CODE | A final label format before the implementing act is identified and reviewed. |
What this does not mean
It does not mean Article 28 is itself a universal Digital Product Passport regime. It creates a label/data-carrier obligation for defined permanent-magnet products.
It does not mean the missed implementing-act deadline starts the two-year clock. The regulation ties the clock to entry into force of the implementing act.
It does not mean the same information can be duplicated indefinitely. If another Union act requires a product passport for the product, Article 28 specifically tells businesses where the magnet information belongs.
It does not mean every motor or appliance is automatically in the same application position. Product type, magnet type, exemptions, sector-specific law and the special 24 May 2029 timing for certain products all matter.
What would change this page
Recheck immediately when:
- the Article 28(2) implementing act is adopted or published;
- its entry-into-force date becomes known;
- Article 28 product/CN scope is supplemented;
- sector-specific Union legislation displaces Article 28 for a product class;
- a product-specific DPP act changes how the magnet information is carried.
Keep exploring
Next question: when two EU regimes both want digital information on the same product, should they create two carriers or reuse one governed record?
Primary sources
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EU law
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EU law
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EU law
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