How do I verify whether my supplier's data are correct?

Consistent data: recognise it by the measurement method used

Data from a supplier is consistent when it has been produced using a test, measurement or calculation method that is reliable, accurate and reproducible — this is the principle laid down in Article 39 of the ESPR (Regulation (EU) 2024/1781) for environmental product data. A first check therefore does not consist of verifying the figure itself, but of establishing how the supplier arrived at that figure: which standard or method was used, and is that method suitable for repeatedly producing the same result. Additionally, there is a second point of attention: Article 40 ESPR prohibits the use of means that cause the performance of a product during a test to differ from performance under normal use, and prohibits design choices intended to cause performance to deteriorate over time. Signals of this — results that appear to apply only under test conditions, or a supplier who cannot provide justification — are a reason to ask further questions.

For manufacturers and importers, not for a general supplier check

These two articles are written for the market participant responsible for the conformity of a product: the manufacturer, and where applicable the importer acting in their place. For them, it is important that the data that ultimately ends up in a product passport is based on sound methods and not on circumvention. What these articles do not regulate is a general reliability check of a supplier as a business — it is not about their financial stability, supply security or administrative organisation. It is specifically about the manner in which a product data point has been measured or calculated. It is also not a task that lies with furnipas.eu: the platform compiles the passport from the data supplied and does not itself carry out laboratory tests or audits.

A fixed date is still lacking

When these obligations become concrete for furniture depends on when a product-specific delegated act under the ESPR comes into force for furniture — it is in this that the requirements and corresponding measurement methods are laid down for each product group. That act does not yet exist for furniture. According to the European Commission's work plan for 2025-2030, it is expected around 2028, and application for furniture — and with it the start of furnipas.eu — could follow around 2030. Both years are planning, not a fixed date. Until the delegated act has been published, there is no legal obligation for furniture arising from Article 39 or 40; however, it may be useful to already work according to the approach set out in the next section.

What this means: four steps in practice

In the order in which this is usually tackled: first, the supplier is asked which test, measurement or calculation method was used for a stated value, and whether that method complies with a recognised or harmonised standard — this is the core of Article 39. Subsequently, the supplier is asked for the underlying test report or the calculation itself, not just the end result, so that the source of a figure can be traced. Thereafter, attention is paid to possible signs of circumvention: a value that is unusually favourable compared to similar products, or a supplier who cannot explain why a result under test conditions differs from performance under normal use — this relates to Article 40. Finally, it is documented which method and which source belong to which data point, so that this remains traceable later when compiling a product passport. For a judgment on a specific case — for example whether a concrete method is sufficient — the official text of the regulation or the associated delegated act is the appropriate source, not a general assessment.

The legal basis: Article 39 and 40 ESPR

Article 39 of the ESPR requires that data on ecodesign requirements are established using methods that are reliable, accurate and reproducible, and that they align as much as possible with generally recognised, harmonised methods. Article 40 ESPR prohibits the use of software, hardware or algorithms that cause a product's performance during testing to deviate from performance during normal use, and prohibits design aimed at automatically degrading performance over time or use. Both articles thus establish the basis for what a "sound" data point is: one that has been established according to a sound method and is not the result of any form of circumvention.

If you are already working with suppliers, you can use this moment to record which method and which standard apply to a supplied data point, and to preserve underlying test reports — so that this documentation is available once the delegated act for furniture is in place and the question becomes concrete.

This is based on

The regulation itself is available on EUR-Lex. We refer per statement; you do not need to believe us.

What you concretely have to do

What is expected of you

A company that compiles a product passport from supplier data processes information that it usually has not itself measured or tested. The ESPR (Regulation (EU) 2024/1781) therefore sets requirements for the way in which data are substantiated, even if that data come from a third party.

Substantiation with recognised methods

Article 39 of the ESPR concerns the test, measurement and calculation methods used to demonstrate that a product complies with the requirements applicable to that product category. For a company with 10 to 100 employees, this means in practical terms that a claim about, for example, recycled material, origin or composition cannot be left without basis: there must be a method behind it that the supplier can name and that (once the delegated act for furniture is in place) aligns with what is laid down in it. Anyone who takes over data without knowing which method is behind it also does not know whether that method will later align with the requirements.

No circumvention or degradation of performance

Article 40 of the ESPR prohibits products, software or components from being designed or configured in such a way that test results are more favourable than actual performance during normal use. This article is primarily aimed at the manufacturer of the product, but is relevant for anyone passing on data from a sub-supplier: a passport based on results that are not representative of normal use passes on a distorted picture, even if the company itself has done nothing to manipulate it.

Checking whether the source of the data aligns with what is requested

For a medium-sized company, the practical work is mainly: checking whether what the supplier delivers matches which data you must request from your furniture supplier. A supplier that names a percentage of recycled material without explanation of the calculation provides a different type of data than a supplier that provides a test report with method and date. The difference is not in the figure itself, but in the question of whether that figure can be traced back to a method.

Where things go wrong in practice

Figures without method. A supplier provides a percentage or value (for example for recycled content or emission values) without stating how it was determined. The company that compiles the passport takes over the figure because it "comes from the supplier", without asking for the measurement method.

Different suppliers, different figures. For the same component, purchased from multiple suppliers, the stated values differ from each other without a clear reason. This occurs especially with the same component from different suppliers, whereby the passport should contain different data per batch or per supplier, but in practice a single average or the most favourable figure is used.

Test report that does not match the delivered product. A supplier sends a test report that relates to a different composition, colour or dimension than what is actually delivered. The report exists, but does not cover the content that the passport suggests.

Origin data that cannot be traced. For wooden components, a country of origin is stated, but without underlying documentation such as a delivery note or certificate. See also what is at stake in recording the origin of the wood: a claim about origin without a paper trail is difficult to verify, let alone defend if questioned later.

Sub-contractor that does not provide data. For semi-finished products supplied by a sub-contractor, there is often no substantiation at all, because the sub-contractor does not see itself as a "supplier of passport data". This occurs specifically in the context of the question of whether a sub-contractor supplying semi-finished products must also provide passport data — a question that must be answered before the passport is compiled.

What you can put in order now

An overview per data item of the method used. Not only the figure or claim itself, but also: which test, measurement or calculation was applied, and by whom.
Test reports and certificates, linked to the specific delivery. A report that cannot be linked to a batch, article number or delivery is difficult to use as substantiation.
Correspondence in which clarification of a figure has been requested. If a supplier provides a value without a method, a retained question about it (and the answer, or the lack thereof) is useful for later.
Agreements on data delivery in the procurement contract. Establishing in advance which substantiation is expected for which data prevents having to clarify this afterwards. See how the delivery of passport data can be laid down in the procurement contract for the approach to this.
A file per component with multiple suppliers. When procuring the same component from different parties: a separate set of data and substantiation per supplier, instead of one average value.
Documentation of the assessment in case of doubt. If data cannot be completely verified but is still used, it is useful to document which steps were taken to check the data and which substantiation was and was not available. This is also relevant to the question of whether passport data must be checked by an independent party, a question that is still being worked out per product group.
For imports from outside the EU: extra attention to the data delivery. Data from a supplier outside the EU requires a slightly different approach, both in what is requested and in how it can be checked; see how to request passport data from a supplier outside the EU and the broader explanation about what the product passport means for imports from outside the European Union.

This is not legal advice. This page provides general information about the legislation that this platform concerns. We do not know your situation. If 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 2026-08-22. Is something wrong? Let us know — corrections take priority.