I use multiple suppliers for the same component how does the passport work in that case

Each supplier provides his own data for his own component

When a component is sourced from two or more suppliers, each supplier provides data on what he himself produces or supplies — the passport follows the component as it is actually incorporated into a specific product, not an average or a collection of all possible sources. This means that a product passport for a specific batch or model contains precisely the data from the supplier who supplied that unit, and that different suppliers may also have different underlying data, as long as the end product meets the requirements with it.

For whom this is relevant and where the boundary lies

This applies to manufacturers and importers who deliberately work with double or multiple sourcing — for example to spread supply risk, compare prices, or because a component is sourced regionally. This always concerns functionally identical or mutually interchangeable components that end up in the same end product. It does not concern the situation in which one supplier supplies components for product group A as well as product group B; that question — one supplier, multiple product groups — is addressed in the approach when a supplier provides components from different product groups. Nor does it concern the situation in which a supplier is replaced during the life of a product; that is a separate question, addressed in what changes if a supplier switches during use. Here it specifically concerns: at one point in time, for one component, multiple simultaneous sources.

What is already established at this moment and what is not

The obligation to maintain a digital product passport is introduced separately for each product group and does not yet automatically apply to every product — when this will apply to a specific product group is described in the question when the product passport becomes mandatory. What is already established, regardless of the date when a product group is due, is the principle in Article 38 of the ESPR: actors in the supply chain — including suppliers of components — are required to provide the data necessary to meet the requirements of the passport. This principle does not change based on the number of suppliers; it applies to each supplier individually, regardless of how many other suppliers also supply the same component.

How this is tackled in practice

The first step is to gain clarity on which data each supplier must provide, and for all suppliers of the same component this is in principle the same set — which data exactly this is, is described in the data requested from a supplier. The second step is that this obligation is established per supplier, for example in the purchase contract, so that it does not turn out afterwards that one supplier cooperates and the other does not — how this is regulated contractually is covered in the recording of passport data in a purchase contract. The third step is a method of administration that makes it clear which supplier belongs to which batch, serial number or production run, so that the passport of a specific unit always refers to the correct underlying data and not to a supplier who did not supply that unit. The fourth step is verification: the data of one supplier is checked in the same way as that of the other, without assuming that a supplier who has been used for longer automatically supplies more reliably — how this verification looks is covered in the verification of supplier data for accuracy. When one of the suppliers does not provide the required data, this does not change the obligation for the end product — that situation, and what can be done about it, is described in what to do if a supplier does not provide the data.

A point of attention that applies specifically when sourcing the same component from multiple suppliers: the data must be mutually comparable and traceable. Article 39 of the ESPR concerns the test, measurement and calculation methods used to demonstrate that a product meets the requirements, and these methods are fixed per product group — which means that two suppliers of the same component cannot simply use their own measurement method if the results are no longer mutually comparable as a result. Article 40 of the ESPR furthermore concerns the prevention of circumvention and performance degradation: where differences in composition or properties exist among different suppliers that affect the measured performance of the product, this is something that must be reflected in the product passport data — not something that is omitted because it is difficult to administer.

The basis: Article 38, Article 10, Article 39 and Article 40 of the ESPR

The obligation for suppliers to provide data follows from Article 38 of the ESPR (Regulation (EU) 2024/1781), which sets requirements for actors in the supply chain. What the product passport must contain substantively is set out in Article 10 of the ESPR, and this indirectly also determines what is needed from each supplier to be able to complete it. That the underlying data are produced in a comparable and verifiable manner follows from Article 39 of the ESPR on test, measurement and calculation methods. That differences between suppliers must not lead to a distorted picture of the actual performance of the product follows from Article 40 of the ESPR on the prevention of circumvention and performance degradation.

What to do now

For those working with multiple suppliers for the same component, the most useful first step is to write down on paper which suppliers are currently being used, what data each already provides, and where the differences lie — that inventory immediately clarifies whether the subject is already relevant for your own product, which can be checked at whether the product passport applies to your product, and what a product passport substantively entails, summarized at the explanation of the digital product passport.

Where this is based on

The regulation itself is on EUR-Lex. We provide references for each claim; you do not have to take our word for it.

What you must do concretely

What is expected of you

If you source the same component from two or three suppliers, you effectively have multiple versions of the 'same' component: identical in specification to the purchasing department, but potentially different in origin, composition or test results. The product passport must follow that reality, not the simplified version of it.

Each product variant requires its own, correct data

Article 10 of the ESPR (Regulation (EU) 2024/1781) sets requirements for the content and accuracy of the digital product passport. This directly relates to the situation with multiple suppliers: if supplier A provides a component with a different alloy, coating or origin than supplier B, these are in principle two different sets of data for the product passport, even if the component has an identical name on the drawing and the purchase order. For a company with 10 to 100 employees, this means that the purchasing administration and the product passport data must remain linked: for each batch or delivery, it must be traceable which supplier made the component and what data are associated with it. What exactly is requested is described on the page on which data you request from your product supplier.

Actors in the supply chain provide their share of the information

Article 38 of the ESPR addresses the obligations of actors in the supply chain. In practice: every supplier of the component is itself a link that must provide data about what it has manufactured or supplied. With one supplier, that is straightforward — with multiple suppliers for the same component, a situation arises in which it must be checked separately for each supplier whether the information is complete and current. That is more coordination work than with a simple chain, but the supplier's obligation to deliver does not change based on the number of suppliers.

Test and measurement methods must be comparable

Article 39 of the ESPR describes the test, measurement and calculation methods used to meet the requirements. With multiple suppliers of the same component, the question is relevant whether all suppliers have measured or tested according to the same method. A reported figure on, for example, recycled content or energy consumption only makes sense if it is clear according to which method it was determined. Differences between suppliers in measurement method lead to figures that do not simply sit next to each other in one passport, or that must be explained separately per variant.

No circumvention through supplier selection

Article 40 of the ESPR addresses the prevention of circumvention and performance degradation. This article is relevant when switching between suppliers, or using suppliers interchangeably, would result in the actual composition or performance of the product being represented as worse than it actually is — or conversely, more favourably. With multiple suppliers alongside each other, this is a real point of attention: the passport must describe the component actually delivered, not an average or a "best case" version of it.

Where things go wrong in practice

A few situations come up repeatedly with companies that source the same component from multiple suppliers.

One passport text for all suppliers. The component has one article number in the ERP system, and one passport text is created based on data from the first or largest supplier. The other suppliers are not asked separately, with the result that the passport is actually incorrect for part of the delivered products.

Batches are not kept separate. Components from different suppliers end up in the same storage location and are not labelled by origin. When the passport needs to be linked to a specific end product, it is no longer possible to determine which supplier delivered the component.

Differences in measurement method are not noticed. Supplier A reports a percentage of recycled material based on a different calculation method than Supplier B. Both figures are used side by side without explanation, even though they are not directly comparable.

Switching suppliers without reviewing the passport. A purchasing department switches between suppliers based on price or delivery time, without notifying whoever manages the passport. See also the page on what happens when you switch suppliers during use.

Sub-contractors of the suppliers remain out of view. With multiple suppliers, there is a greater chance that one of them in turn sources a component from a sub-contractor, without notifying you. What can be requested in that case is on the page about the data from a sub-contractor who manufactures a component.

What you can document

With multiple suppliers for the same component, it is worth arranging a few things in writing beforehand, so that the passport remains aligned with what is actually being delivered.

A supplier list per article number, with any known variations in composition, origin or test method noted for each supplier.
Batch or delivery registration, so that for each delivery it is possible to determine which supplier is the source, even when the component is internally recorded under one article number.
Agreements in the purchase contract on the delivery of passport data per supplier, including the moment when data is submitted and updated. How this is documented in a contract is described on the page about agreements in your purchase contract.
Continuous verification of incoming data, whereby for each supplier it is checked whether the supplied information matches what was previously received. A procedure for this is described on the page about verifying data for accuracy.
A documented explanation of differences in measurement method, so that during an audit or when asked by a customer it is clear why figures from supplier A and supplier B are not automatically the same.
A procedure in case a supplier does not deliver, with a reference to the steps to be taken, described on the page about what to do if your supplier does not provide the data.

Whoever documents these matters builds up an administration that not only supports the passport, but also remains in place for cross-product group procurement — for example when the same supplier delivers components from different product groups, a situation that is separately addressed on the page about a supplier for multiple groups.

This is not legal advice. This page provides general information about the regulations that this platform concerns. We do not know your situation. If you are in doubt about your own case, consult a lawyer or the competent supervisory authority.

Written with AI based on the sources above, reviewed by a human on 2026-09-05. Is something incorrect? Let us know — corrections are given priority.