what data do I request from a subcontractor who manufactures a component

The material, origin and technical data of the component

When a subcontractor manufactures a component for you, you essentially request the same type of data that you will later need yourself to compile the digital product passport of the final product: what the component contains, where it comes from, and how it performs. In concrete terms, this concerns material composition (including any substances that must be reported), origin of raw materials, an article or type designation by which the component can be uniquely identified, and the technical data relevant to durability, repair or recycling — think of weight, service life, repair options or recycling percentages. Which data exactly is needed depends on the product group into which the final product falls, because the delegated regulation drawn up for each product group determines the exact content of the passport.

For suppliers in the chain, not for the end manufacturer itself

This issue arises as soon as you have a component manufactured by a third party — a subcontractor, supplier or specialized component maker — and incorporate that component into a product that you yourself place on the market. The subcontractor in that relationship is an "actor in the supply chain": someone who must provide information, but is not themselves responsible for compiling or publishing the digital product passport. That responsibility lies with the party placing the final product on the market, typically the manufacturer. This distinction is important: you request data from the subcontractor about their component, not a complete passport. They provide the building blocks, you (or the party compiling the passport) process those into the whole. This does not apply to situations in which the subcontractor themselves manufactures a self-contained marketable product that comes onto the market independently — in that case they are themselves the responsible manufacturer for that product, with their own passport obligation.

Even if the component is sourced from outside the EU, this changes who must provide which information; this concerns the role of the importer, who has their own obligations alongside those of the manufacturer. What importing components or products from outside the EU means for the passport obligation is worked out separately in what the product passport means when importing from outside the European Union.

No fixed date yet, but a fixed principle

No general entry-into-force date is yet known for when this obligation for subcontractors takes effect; that follows for each product group from the delegated regulation drawn up for it by the European Commission. What is fixed, however, is the principle from the ESPR itself: as soon as a passport obligation applies to a product group, actors in the supply chain must provide the data needed to comply with that obligation. Until a product group is specifically designated and the associated delegated regulation is published, there is no legal obligation to provide or request this data — although it may be practically wise to set up the information flow with subcontractors now, so that it is in place at the moment the obligation comes into force. When the passport becomes specifically mandatory for a product group can be followed via the page on when the product passport becomes mandatory for products.

How you tackle this: from question to recording

The first step is to determine which product group the final product falls into and which data the associated delegated regulation requires for that group — this determines exactly what you must request from the subcontractor. Next, you request those data specifically for the component: material composition, origin, and the technical characteristics named in the regulation. Because a component is often also supplied separately to other customers or can be replaced, it makes sense to immediately think about how you will handle a change of supplier during the product's service life — this is worked out in what happens to the passport if you change supplier during use. Then record the agreement on delivery of this data, preferably not scattered across emails but in the contract with the subcontractor, including what happens if data is missing or changes. A good approach to this is described in how you record the delivery of product passport data in your procurement contract. Next, check the supplied data for consistency and accuracy before you process it in the passport of the end product — incorrect data from a subcontractor do not automatically become correct just because they end up in another product's passport. If the subcontractor works with multiple variants of the same component for different customers, it is advisable to discuss beforehand how he distinguishes between those variants in his data delivery.

Justification: articles 38, 10 and 29 of the ESPR

That actors in the supply chain — including subcontractors who manufacture components — may be required to supply information needed for the product passport follows from article 38 of the ESPR (Regulation (EU) 2024/1781). Which data a passport must exactly contain, and thus which data are ultimately requested from the supply chain, is set out as a general framework in article 10 of the ESPR, with the specific implementation per product group in the corresponding delegated regulation. For situations in which a component is sourced from outside the EU, the obligations of the importer are relevant, as set out in article 29 of the ESPR.

Anyone getting started with this can best first look at which data is generally requested from a product supplier on the page which data you request from your product supplier, and then tailor this to the specific situation of a subcontractor who manufactures one component for the end product.