I am changing suppliers must the product passport be adjusted

What you must do concretely

What is expected of you

A supplier change is not automatically a passport change, but in most cases something does change in the data that appears in the passport. The passport describes the specific product as it is placed on the market, and a different component, a different manufacturer of a component or a different origin can mean that the underlying data no longer match.

Check whether the product itself changes

The first step is not legal but factual: is the product you sell after the change still the same product? Article 9 of the ESPR (Regulation (EU) 2024/1781) links the passport to the product as it is placed on the market, including the characteristics that are relevant to the requirements of the delegated regulation for the product group concerned. If a material, a composition, a country of origin of a component, or a property that appears in the passport changes, then in practice there is a matter of changed information that must be reflected in the passport. If the product remains functionally and materially identical and only the party supplying it changes, there is a greater chance that the existing data will largely remain in place — but this must be checked, not assumed.

Obtain new data from the new supplier

For a company with 10 to 100 employees, a supplier change in practice means that the entire process of requesting data is repeated, even if it has already been done once with the previous supplier. Article 38 of the ESPR sets requirements for actors in the supply chain for providing information needed for the passport, but that does not mean that every supplier provides the same data in the same way. What data exactly that is and in what form is described at which data must I request from my product supplier. In the event of a change, it is advisable to ask that question again from scratch, even if the new component appears similar to the old one.

Check whether the new data are correct

New data from a new supplier are not automatically more or less reliable than the old ones. They must be reviewed in the same way before they end up in the passport. How this review is arranged in practice is described at how do I check whether the data from my supplier are correct. When switching suppliers, this is a good time to review whether the new supplier delivers the same components, materials and properties as described in the specification that was requested from the old supplier, or whether there are differences that are not immediately apparent.

Document what has been changed and when

Article 10 of the ESPR sets requirements for the management and currency of information in the digital product passport. This directly concerns a supplier switch: if the passport no longer matches the delivered product after the switch, a discrepancy arises between what the passport states and what is actually in the product. For a company, this means that the switch is a documentation moment — not only "we have switched to supplier B", but also when this happened, for which products or product series, and which data was adjusted as a result.

Importers with an additional point of attention

Whoever imports products from outside the EU and switches suppliers faces an additional layer. Article 29 of the ESPR describes obligations for importers, including checking whether the manufacturer has prepared the required information and the passport. If the supplier from outside the EU changes, the person acting as the manufacturer in that chain often changes too, and with it, who is responsible for the passport. What this means in practice is explained at what does the product passport mean if I import products from outside the EU.

Where things go wrong in practice

A common situation is that a company replaces a supplier for exactly the same component, assumes that nothing changes, and leaves the passport unchanged — while the new supplier uses a slightly different composition or a different country of origin.

Another situation arises when the new supplier does not deliver the requested data on time or in full, as a result of which the passport remains on outdated information while the product has already been switched in reality.

Also difficult: a company switches suppliers for one component within a composite product, but forgets that this component falls under a different product group than the rest — a situation that is addressed at my supplier delivers components from different product groups — how do I handle that.

Furthermore, it happens that a company temporarily works with two suppliers during the transition — the old one for delivery of existing stock, the new one for new production — without it being clear which passport belongs to which batch.

Finally, it goes wrong when agreements with the old supplier about data delivery silently expire at the switch, without comparable agreements being made with the new supplier.

What you can document

• An overview of which products or product series have been affected by the supplier switch, with the date of the switch.
• The specification that was submitted to the new supplier, and whether this differs from the specification that applied to the old supplier.
• The new data received, including the way in which it has been checked for accuracy.
• Contractual agreements with the new supplier on continued provision of data, as described at how do I record the delivery of passport data in my procurement contract.
• A note on any overlap period during which products from the old and new supplier are in circulation at the same time, with a link showing which passport belongs to which batch.
• If applicable: a confidentiality agreement with the new supplier regarding the data shared for the passport, see can I request a confidentiality agreement from my supplier regarding passport data.