what do I do if I purchase the same component from different suppliers

Each procurement variant receives its own product passport

If the same component — for example an upholstery fabric or sheet material — is procured from multiple suppliers, in principle a separate set of product passport data is required for each supplier. The product passport describes a specific product as it is actually assembled and produced, and that composition can differ per supplier: different raw material, different production location, different chemical treatment. Even if the component appears identical and serves the same function in the furniture, the underlying information — origin, material composition, recycled content, test results — can differ per supplier. One passport that speaks "on behalf of" multiple suppliers is therefore usually not tenable; the passport must correctly describe the end product as it is actually brought to market.

For whom this applies and where there is flexibility

This mainly applies to manufacturers and project furnishers who deliberately work with multiple suppliers for the same component — for reasons of supply security, price or sustainability. The obligation to provide accurate data lies at the level of the product as it is brought to market: each furniture model with a specific fabric or sheet variant is in that sense a separate combination to be described. This does not automatically apply to every small colour or finish variant within the same supplier and the same production method — if the underlying material composition and origin are identical, the passport can possibly be set up for it without requiring a completely new file for each colour code. The distinction that matters is not "does it look the same", but "is the underlying information the same". In case of doubt about what exactly needs to be documented per variant, which data you request from your furniture supplier provides a concrete overview to check against your own procurement practice.

What is already fixed and what is not

When this obligation will concretely take effect for furniture is not yet fixed. The ESPR itself is in force, but the product-specific implementation for furniture must still be established via a delegated act; according to the European Commission's work programme this is expected around 2028, but a definitive date is not yet available. As soon as that act is published, the date will be stated here. Until then, it is already established that the ESPR sets the general framework for what a passport must contain and how information must be tested, measured and calculated — that already provides direction for setting up procurement processes, even though there is no legal obligation yet.

How this is addressed in practice

Anyone who already works with multiple suppliers for the same component should first inventory which data are available from each supplier and which are not — that overview is the basis for everything that follows. Next, it is useful to determine whether the suppliers actually use different materials or production processes, or whether it is essentially identical input that merely comes in via a different trade route; that distinction determines whether one basic file with minor variants will suffice later, or whether multiple fully separate product passports are needed. After that, it is worthwhile to establish agreements on the provision of this data with each supplier separately, so that it does not turn out by chance that one supplier can provide the data and the other cannot — how to record the provision of product passport data in the procurement contract describes how this is arranged in practice. Finally, it is advisable to have a fixed way of checking that the data provided by one supplier have not been silently adopted for the other, as that is precisely the risk with this type of multi-sourcing: data that are correct for supplier A are then incorrectly linked to the product of supplier B. Anyone who wants to safeguard this can follow the approach described in how the supplier's data are verified for accuracy use as a checklist per purchasing relationship.

The basis in the ESPR articles

That the passport must describe the specific product as it is actually composed follows from the requirements for the digital product passport in article 10 of the ESPR (Regulation (EU) 2024/1781), read in conjunction with the ecodesign, performance and information requirements of articles 5 to 7 of that regulation: those requirements are linked to the actual characteristics of the product, not to a generic product category. That information must be based on reliable test, measurement and calculation methods is stated in article 39 of the ESPR — which means that data from one supplier cannot simply serve as evidence for the product of another supplier. And article 40 of the ESPR, on the prevention of circumvention and degradation of performance, underscores that it is not permitted to hollow out the core of the information obligation through administrative shortcuts — such as one passport for multiple factually different products.

If a company currently works with multiple suppliers for the same component, it is best to start with an overview of what data each supplier can already provide and where the gaps are; from there it can be determined whether contractual agreements, additional questions to the supplier or a separate approach per variant is needed.

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

If a fabric or sheet material comes from multiple suppliers, the starting point of the ESPR does not change: each product placed on the market must have a passport that is correct for precisely that product. The component "the same fabric" is therefore not legally one thing with one passport, but as many variants as there are sources.

Each supply chain is a separate information stream

Article 7 of the ESPR (Regulation (EU) 2024/1781) requires information that correctly describes the characteristics of the supplied product. If a sofa with the same upholstery fabric sometimes comes from factory A and sometimes from factory B, the composition, origin or treatment of that fabric may differ per supplier — even if the label, colour code or article name is the same. For a company of 10 to 100 employees, this practically means that the purchasing administration must be able to show which batch was purchased from which supplier, and which passport data belong to which batch. Without that link, there is a risk that data from supplier A will be used for a product that actually comes from supplier B.

Comparability between suppliers is not automatic

Article 39 of the ESPR concerns the test, measurement and calculation methods used to meet the requirements. Two suppliers of the "same" board may arrive at different figures if they do not use the same method to measure, for example, emission values or recycled material. For a processing company, this means that combining supplier data into one passport text cannot simply be done: first it must be clear whether the underlying measurements have been carried out in a comparable manner. How do I verify whether my supplier's data are correct? goes into more detail on how to assess that.

No degradation via a detour

Article 40 of the ESPR is aimed at preventing circumvention and degradation of performance. This article is relevant as soon as a company could be tempted to, with two suppliers with different performance levels, systematically report the most favourable figures while in practice material from the other supplier is also processed. The purpose of this article is that the passport information reflects the actual composition of the supplied product, not a favourable average or a choice based on what works best.

The passport follows the product, not the article number

Article 10 of the ESPR describes the requirements for the digital product passport itself, including the link between passport and the specific product. An internal article number that combines two suppliers under one line in your range is convenient for your own administration, but for the passport, what matters is the actual composition of the component incorporated into the furniture. This also relates to the question Does the digital product passport apply to my furniture?whether I should create different passports when I source the same component from different suppliers — furnipas.eu

Where things go wrong in practice

because the obligation applies per product and not per product category in your own catalogue.

A few situations come up frequently with companies that work with varying sub-suppliers: One passport text for two sources.

An upholsterer consistently uses the same description and the same composition data for a fabric, even though the actual supplier changes per order. Once one of the suppliers adjusts the recipe, the text no longer applies to part of the inventory. No batch registration.

Purchasing is driven by price and delivery time, but it is not recorded which batch of sheet material from which supplier was incorporated into which series of furniture. If there is a question later, it is no longer possible to trace which passport belongs to which item. Relying on the most favourable figure.

If one supplier states a higher percentage of recycled material than the other, that figure is used for the entire range, including batches from the other supplier. This directly conflicts with the purpose of Article 40 of the ESPR. Incomparable test methods mixed.

One supplier provides a test report according to a standard, the other provides only a declaration of performance without a clear measurement method. Both are placed in the same passport fields without distinction, even though they are not directly comparable. Changing supplier without reviewing passport. What data must I request from my furniture supplier? A new supplier is added alongside the existing one to spread supply risk, but the passport is not updated because it would be "the same fabric". The question

What you can put in order now

is then not revisited with the new supplier.
An overview per fabric or sheet type of which suppliers deliver it, with the corresponding article or batch codes of each supplier individually.
A link in your own production or order administration between purchase batch and the furniture in which that batch was incorporated, so that a passport can later be traced back to the correct source.
Per supplier, the underlying test reports or declarations, including a note about the method used, so that it is clear whether figures from different suppliers are comparable. How do I document the supply of passport data in my purchase contract? Contractual agreements about when a supplier must notify you of a change in composition or recipe;
provides a starting point for this.
A fixed procedure for when a supplier is added or replaced, including going through the data request again instead of automatically adopting existing passport text.

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, checked by a human on 2026-09-05. Is something not right? Let us know — corrections take priority.