must I update the product passport if I change material supplier
Yes, if the material change affects the recorded data
A product passport describes a specific product as it is manufactured, and if a different supplier provides a different material — a different type of foam, a different wood species, an adhesive with a different formaldehyde emission — then that product's passport no longer matches reality. The passport must then be updated, or a new product variant is created with its own passport. If the supplier changes, but the material itself remains unchanged (the same wood species, the same composition, the same properties), then in most cases nothing changes for the passport, because the passport describes the product's properties and not the name of the supplier.
What does and does not fall under this question
This question concerns the moment when a manufacturer or importer switches material suppliers for a product that already has a product passport, or for which the passport is being compiled. It is therefore about the content of the passport: the materials, the composition per component, and the properties that result from it. It is not about who the supplier is commercially — that name does not in itself need to appear in the passport, unless it is relevant for a mandatory piece of information such as origin or a substance that must be reported. It is also not about incidental deviations within the same specification: if two suppliers provide the same certified material within the same standard, the recorded property does not change. And it is not about how often data must be checked in general — that is a separate question, described on the page about how up-to-date the data in the product passport must be.
The distinction that matters is therefore not "different supplier yes or no", but "different material property yes or no". A manufacturer that switches wood suppliers but continues to use the same wood species with the same properties is in a different situation than a manufacturer that switches to a different type of sheet material with a different adhesive composition.
No fixed date yet, but a fixed obligation once it applies
When the digital product passport for furniture becomes mandatory is not yet fixed. The European Commission's work plan under the ESPR (Regulation (EU) 2024/1781) lists furniture as a product category, and a delegated act with the precise requirements is being prepared, but the date on which that act is published and comes into force is not yet fixed. As soon as that is known, it will be mentioned here. Until then, it is already fixed that the passport, once mandatory, must contain current and correct product information in accordance with Article 9 and Article 10 of the ESPR. This means that the obligation to update the passport when changing suppliers is not a separate rule that can later be dropped — it is a direct consequence of the requirement that the passport must be correct, and that requirement is already fixed, even if the entry date for furniture is not.
How this works in practice when switching suppliers
When switching material suppliers, the first step is to determine whether the material itself changes: the same raw material, the same composition, the same measured properties, or not. If that remains the same, then in most cases there is no reason to update the passport. If the material changes — a different type of plastic, a different metal alloy, a different coating — then the second step is to check which data in the passport are affected by this: the material composition per component (see record materials per component), a possible emission class (see determine the formaldehyde emission class), the proportion of hazardous substances, or the recyclability percentage. What specifically must be stated in the passport about material and composition is described on the page about what data will be included in the product passport for furniture.
The third step is to determine whether this concerns an update of the existing passport, or a new passport for a new product variant. If the resulting product is in practice a different product — different performance, different composition, different expected service life — then a new passport with its own data carrier is the logical choice, rather than overwriting the existing one. If the modification is limited and the product is functionally identical, then an update of the existing passport is more appropriate. For a platform that hosted the passport and provided the QR data carrier, this means in practice that the manufacturer or importer provides the amended material data as soon as the supplier change affects a property stated in the passport.
Where this follows from: Articles 9, 10 and 38 of the ESPR
Article 9 of the ESPR stipulates that the digital product passport contains information about the specific product and is linked to a unique product identification. Article 10 sets requirements for the content and accuracy of that information. Together, these articles mean that the passport must reflect the actual, current state of the product — a material change that alters the composition falls under this. Article 38 furthermore regulates the obligations of actors in the supply chain to provide the necessary information to the party that compiles the passport, which is relevant at the moment when a new supplier provides different material data than the previous one.
What to do
In the event of a supplier change, first check whether the material itself changes (raw material, composition, measured properties) or only the supplier as a party; if the material remains the same, amendment of the passport will in most cases not be necessary. If the material does change, then it is important to provide the amended data as soon as the delegated act for furniture and the associated entry into force date are known, so that the passport or the new product variant is compiled with the correct material data.
This is based on
- Regulation (EU) 2024/1781 (ESPR), article 10 (requirements for the digital product passport)
- Regulation (EU) 2024/1781 (ESPR), Article 9 (digital product passport)
- Regulation (EU) 2024/1781 (ESPR), Article 38 (requirements for actors in the supply chain)
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 product passport is linked to a product, not a supplier. Once the composition of a piece of furniture changes — for example because a different type of chipboard, foam or fabric is used — the information in that passport often changes as well. So the question is not really "must I do something in the event of a supplier change", but "is there a change to the product itself". That distinction determines what must happen in practice.
The data must correspond to the actual product
Article 9 of the ESPR (Regulation (EU) 2024/1781) stipulates that the digital product passport contains information about the specific product to which it applies. For a company of 10 to 100 employees, this means that the passport is not a general description of "a cabinet" but of that cabinet, with the materials that are actually in it. If a supplier switches to, for example, a different type of adhesive or steel fastening material, the question is whether that affects the information stated in the passport — think of the materials per component or hazardous substances. If that is the case, then the existing passport no longer matches the product that leaves the door.
Currency of the data
Article 10 of the ESPR (Regulation (EU) 2024/1781) describes the requirements that the digital product passport must meet, including that the information contained therein is accurate, complete and current. A supplier change that leads to a different material composition, a different emission level or a different origin of a raw material, in practice affects precisely that kind of information. How often and at what time data must be updated is described on the page about how up-to-date the data in the product passport must be; for a supplier change, this applies as a starting point for the question of when an amendment is in order.
Providing information within the supply chain
Article 38 of the ESPR (Regulation (EU) 2024/1781) describes the requirements for actors in the supply chain: information relevant to the product passport must be communicated to the party that compiles or manages the passport. For a furniture manufacturer or importer, this means that a new material supplier is in practice the source of data that must first be verified and then passed on to the passport. Without that transmission, a passport emerges that actually still describes the old supplier, even if the product has already changed.
Assessing whether the change is material
Not every supplier change affects the content of the passport. A new supplier that delivers exactly the same material, with the same composition and the same properties, changes nothing in what the passport states. A new supplier that delivers a different type of foam, a different type of adhesive or a different metal does change it. This assessment lies in practice with the party that assembles the product, and is directly connected to the question of which data exactly must be included in the furniture product passport; see which data are included in the product passport for furniture for the overview of that.
Where things go wrong in practice
Procurement switches suppliers without informing the quality department. At many companies, the choice for a new raw material or component supplier runs through procurement, while the passport is managed by quality or product development. If those two departments do not coordinate structurally, the product changes without the passport moving along.
Switching only on price and delivery time, not on composition. A new supplier of, for example, sheet material is often assessed on price, delivery time and quality of finishing — not automatically on the exact chemical composition or formaldehyde emission. Yet the latter is relevant to the passport, see also the page on how the formaldehyde emission class of a piece of furniture is determined.
Documentation of the old supplier remains in the passport. When switching, sometimes only the new delivery is physically processed, while the underlying data — test reports, certificates, material declarations — are still from the previous supplier. The passport then refers to information that no longer fits the delivered product.
No visibility into what the new supplier actually delivers. Some suppliers provide less detailed information than the previous one, for example no statement of hazardous substances per component. This makes it difficult to keep the passport complete, even when one would want to.
Updating the passport is postponed until a "logical moment". Some companies want to wait with updating until a larger model change, while the supplier switch has already led to a different material composition earlier. Between the moment of switching and the moment of updating there is then a period in which the passport does not correspond with the product.
What you can put in order now
- An internal agreement between procurement and the department managing the passport, about when a supplier switch is reported.
- A checklist per new supplier: which materials are delivered, and on which points of the passport this may have an impact — think of materials per component, hazardous substances or recyclability.
- Declarations and test reports from the new supplier, archived alongside (not instead of) those from the previous supplier, so that it remains traceable which passport went with which delivery.
- A file in which per product modification it is recorded whether the passport has been updated, and on which date — relevant in combination with the question of how often data must be updated.
- Correspondence with the new supplier about the provision of data needed for the passport, so that the transmission of information within the supply chain is demonstrably arranged.
- An overview of which changes do and do not constitute a material change affecting the passport, as justification for the choices made.
- If applicable: an adjusted calculation of the CO2 footprint or recyclability percentage, when the new materials differ from the old ones — see the pages on calculate the CO2 footprint of a piece of furniture and calculate the recyclability percentage of a piece of furniture.
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.