Which data must I request from my supplier of products?

What you must do concretely

What is expected of you

As a manufacturer or importer, you compile the digital product passport yourself, but most of the content does not come from your own administration. It comes from the parties that supply you: component makers, raw material suppliers, assembly companies. Article 38 of the ESPR (Regulation (EU) 2024/1781) establishes that actors in the supply chain have obligations regarding the provision of information needed for the passport. What this means in practice breaks down into a few recognisable components.

Knowing which data the passport needs

Article 10 of the ESPR describes what a digital product passport must contain in terms of information. For a company with 10 to 100 employees, this first means translating it: determining which of these information requirements apply to which component or raw material, and thus which supplier they must be requested from. This is not a one-time exercise but something that differs per product group and per delegated act — which is why it makes sense to first clarify whether the product passport applies to your products and which data categories are involved.

Actually requesting data from the supplier

The obligation under Article 38 works in practice in two directions: the supplier must provide something, but you must ask for it — and specifically enough. For a company of this size, this usually means that someone is designated to maintain a list per supplier: which data are needed, which have already been received, which are still missing. For companies with a handful of fixed suppliers this is manageable in a spreadsheet; with a broader procurement package it quickly becomes confusing without a fixed format.

Receiving data on time and in the correct form

It is not enough that the data arrive at some point — they must be there before the passport is compiled and published, and in a form that can be processed. For a production company, this means that data provision becomes part of the procurement process itself, not something that is followed up on afterwards. In practice, this works best if the supply of passport data has a fixed place in the procurement terms, so that it is not a matter of asking and hoping but of an agreement that is set in stone. How this is concretely shaped is described in how you record the supply of passport data in your procurement contract.

Data can be substantiated

What a supplier provides becomes part of your passport and thus (partly) your responsibility to the outside world. This does not mean you have to measure or test everything yourself again, but it does mean there must be something to fall back on if the accuracy of a piece of data is questioned. For a company without its own laboratory or testing capacity, this is often the most underestimated part: requesting the figure is one step, documenting the substantiation behind it a second.

Where things go wrong in practice

A few situations come up repeatedly with companies that tackle this issue.

First: the data are only requested at the moment the passport needs to be made, while the supplier is long gone from the process to still deliver something quickly, or the order has long been completed. Second: a general request is sent ("send us your product data") without specifying which data exactly are needed according to Article 10, after which the supplier sends back something that does not match what the passport requires. Third: with an assembly product, it is forgotten that not only the direct supplier but also a subcontractor behind them must provide data — which creates a gap in the chain that is only noticed late. What to ask about in this context is described in which data you request from a subcontractor who manufactures a component. Fourth: data are provided, but no one checks whether they are correct — until a customer or supervisory authority asks about it. And fifth: a company works with multiple suppliers for the same component, for example to spread supply risk, and discovers that each supplier provides different data in a different format, meaning the passport would have to differ per batch. How this is handled is described in what to do if you use multiple suppliers for the same component.

Another recurring pattern is that a supplier simply does not provide data — through unwillingness, lack of knowledge, or because the supplier itself does not know where the information should come from. What can be done about this is described in what you can do if your supplier does not provide the data.

What you can document

A number of documents and agreements make requesting supplier data manageable rather than something that is reinvented each time:

• A data specification per product group: a list of which information elements from Article 10 of the ESPR belong to which component or which raw material, so that a purchasing manager does not have to figure out each time what is needed.
• A fixed part of the purchase contract on the provision of passport data, including what happens if that data is not provided or proves to be incorrect. A detailed example can be found in the agreements that can be included in a purchase contract.
• A control procedure for incoming supplier data, so that not every figure is blindly accepted. See how a supplier's data are checked for accuracy for the approach to this.
• An overview per supplier of what has been provided and what is still missing, maintained as a fixed part of the procurement file instead of loose email exchanges.
• A confidentiality agreement for data that the supplier considers confidential, so that requesting detailed information does not stall due to cold feet. See whether a confidentiality statement can be requested from the supplier.
• A procedure for supplier change, so that it is clear what happens to the existing passport once the supplier is changed. More information on this at whether the product passport must be adjusted in case of a supplier change.
• Additional agreements for imports from outside the EU, where the question of who supplies which data gains an extra layer. See what the product passport means when importing from outside the European Union.

These provisions make requesting supplier data less dependent on the memory of one purchasing manager, and give a company something to fall back on once a dispute arises over who should have supplied what.