must a subcontractor supplying semi-finished products also provide passport data
Yes, a link further down the chain also supplies data
A subcontractor supplying semi-finished products — a panel, a frame, an upholstery, a fitting — falls under the same logic as any other supplier in the chain: whoever supplies a component or material that ends up in the end product also supplies the data needed about it for the passport. The manufacturer placing the end product on the market is the one who must compile the passport and is responsible for it, but they can only deliver what they know. If that information is with a subcontractor, then that information must come up somewhere in the chain — otherwise a gap in the passport will be created that the manufacturer themselves cannot fill.
Who this applies to, and where the boundary lies
This applies to every party that contributes to a product that will eventually need a digital product passport: not only the direct supplier to the furniture manufacturer, but also their subcontractors, suppliers of raw materials and intermediate products. The ESPR does not by chance speak of "actors in the supply chain" instead of only suppliers — this refers to the entire chain, not just the first link. What is not included: information that has nothing to do with the product itself, such as internal business processes of the subcontractor, or data that is not part of the requirements for the passport. The subcontractor supplies product information — origin, composition, material properties — not their entire business operations. And the form in which they do so is not fixed: it can be a simple data sheet, just as well as a connection to a system. What matters is that the information is there and correct, not via which channel.
Another distinction that plays a role here: a subcontractor is not automatically the same party as an importer. Whoever brings components from outside the EU obtains an additional layer of obligations that specifically applies to importers — that is a different question than that of the domestic subcontractor supplying semi-finished products. Whoever deals with this, can read more about it at what the product passport means for imports from outside the European Union.
From when does this apply
There is no fixed date yet when this applies to furniture. The ESPR is the framework regulation; which product groups are addressed when is worked out per product group in a delegated act. For furniture, that act does not yet exist — the European Commission's work plan for 2025-2030 mentions a delegated act for furniture as expected for 2028, but that is a schedule, not an established obligation. As soon as that act is published, the date will be shown here. Until then, nothing legally changes in what a subcontractor must already supply — but the chain needed for that does not come about from one day to the next. Whoever already works with subcontractors can already inform themselves about what will be expected from the supplier side; see also when the product passport becomes mandatory for furniture and whether the product passport applies to your own furniture.
How to approach this in practice
The first step is to determine which data from the subcontractor is needed for the passport — that overview is described at which data to request from a furniture supplier, and that list applies broadly also to a subcontractor supplying a component or semi-finished product. The second step is to record that: not verbally, not "we'll arrange it later", but as part of the agreement with that subcontractor. How that ends up in a purchase contract is worked out at recording the supply of passport data in a purchase contract — and that applies to a subcontractor just as well as to a regular supplier.
The third step is a plan B, because a subcontractor who does not supply the data on time, not completely, or not at all, is not a theoretical risk. What can be done about that is described on the page about what to do if a supplier does not provide the data. If the component comes from multiple subcontractors or suppliers at the same time — for example because there is a switch between two suppliers of the same fitting — then there is an additional layer to be arranged, detailed at what to do if the same component is purchased from different suppliers. And once the data is in, the question remains whether it is correct — see how to check a supplier's data for accuracy.
The legal basis: articles 38, 10 and 29 of the ESPR
That actors in the supply chain — so not only the party placing the end product on the market — must provide data, follows from article 38 of the ESPR (Regulation (EU) 2024/1781), which specifically sets requirements for actors in the supply chain. Which information should end up in the passport is set out in article 10 of the ESPR, the general requirements for the digital product passport — that article determines the content to which the subcontractor's delivery must contribute. For the party importing components from outside the EU, the specific obligations of article 29 of the ESPR, on the obligations of importers, additionally apply.
What to do now
Anyone already working with subcontractors who supply semi-finished products can best map out that relationship now: which parts come from which party, what information is needed about that, and has that already been documented somewhere. That overview is the basis for both the purchasing contract and for when the delegated act for furniture does exist — and saves investigative work under time pressure.
This is based on
- Regulation (EU) 2024/1781 (ESPR), Article 38 (requirements for actors in the supply chain)
- Regulation (EU) 2024/1781 (ESPR), article 10 (requirements for the digital product passport)
- Regulation (EU) 2024/1781 (ESPR), Article 29 (obligations of importers)
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 furniture maker who purchases semi-finished products — a frame, an upholstered cushion element, a sheet of glued wood — assembles the final product from parts that do not all come from their own production. The question of whether a subcontractor supplying such a semi-finished product must also provide passport data hinges on the position this party holds in the chain and on what information is needed for the passport of the end product.
The chain provides the building blocks of the passport
Article 38 of the ESPR (Regulation (EU) 2024/1781) describes that actors in the supply chain must provide the information necessary to meet the requirements for the product. For a company of 10 to 100 employees, this practically means that not only the end manufacturer collects data, but everyone who supplies a part or material — including a subcontractor who makes a semi-finished product — is involved in obtaining complete data. The subcontractor then provides, for example, material composition, origin or processing data about the part they supply, not the complete passport of the end product. Exactly who provides what data depends on the role in the chain and on what is needed to complete the passport of the assembled furniture.
The passport of the end product must be complete
Article 10 of the ESPR (Regulation (EU) 2024/1781) describes what information a digital product passport must contain. For an assembled piece of furniture — say a sofa with a frame from a subcontractor and upholstery from a second supplier — it is not just what the end manufacturer itself processes or assembles that counts, but also what is in the supplied parts. Practically speaking, this means that a company assembling the end product and providing the passport depends on the data that subcontractors and suppliers provide. If that information is missing, then part of the passport is missing — even if the end manufacturer has everything in order. Exactly what data that is is described on the page about which data you must request from your furniture supplier.
When importing from outside the EU, part of the responsibility shifts
Article 29 of the ESPR (Regulation (EU) 2024/1781) describes the obligations of importers, including checking whether the manufacturer has drawn up the required information and the passport. For a company that has semi-finished products or components made by a subcontractor outside the EU, this means that the role of importer comes as an additional layer on top: not only asking what the subcontractor supplies, but also checking whether this aligns with what the importer's regulations expect. This subject is further elaborated on the page about what the product passport means when importing furniture from outside the European Union.
Where things go wrong in practice
A number of situations recur regularly in practice.
The subcontractor supplies only a technical drawing, no material data. A frame is custom-made, the supplier sends a production drawing and an invoice, but no data on the precise composition of the metal used or the coating. Without that data, the passport of the end product cannot be completed.
The semi-finished product supplier does not see itself as part of the chain. A small woodworking company that only glues sheets for a larger furniture maker sometimes assumes that the obligations lie with the end manufacturer and not with itself. This perception does not align with what Article 38 of the ESPR describes about the role of actors in the supply chain.
Varying information is received from the same subcontractor, depending on the order. When reordering the same frame, the composition turns out to have changed slightly — a different screw, a different type of glue — without this being communicated. For the passport, this makes a difference.
Multiple subcontractors supply the same type of component, with different files. When purchasing from two suppliers alternately for the same product line, there is a risk that the passport does not match the batch actually processed in a specific delivery. This issue comes back on the page about what to do if the same component is purchased from different suppliers.
The subcontractor refuses to share data for reasons of competition. Some suppliers regard material composition or recipe as trade secrets and are reluctant. This bottleneck, and possible ways of dealing with it, is described on the page my supplier does not provide the data — what can I do?.
What you can put in order now
For a company that purchases semi-finished products from a subcontractor, it is practical to have a number of things in writing, regardless of how the regulations actually apply to your own company:
- An overview of which components are supplied by which subcontractor, including contact details and the nature of the processing that has been performed.
- A documented agreement with the subcontractor about what data will be supplied and when. How such an agreement can look like is described on the page about recording the supply of passport data in the purchase contract.
- A file per component or semi-finished product, with material data, origin and any certificates, so that this does not have to be requested again per order.
- A method to check the data supplied before it is processed in the passport of the end product. Guidance on this can be found on the page about checking whether the supplier's data is correct.
- A note of changes in the semi-finished product, such as a different raw material or a different processing method, so that it remains clear which version of the component was processed in which delivery.
This documentation makes it easier to keep track of which subcontractor has supplied which data, and saves work at the moment when the passport of the end product actually has to be put together.
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.