I have multiple suppliers for the same part how does that work with the passport

The passport can differ per supplier

If the same component is purchased from multiple suppliers, it does not automatically come with one and the same passport as a rule. A digital product passport describes a specific product as placed on the market by a specific manufacturer or importer, containing the data that that party has supplied. Two suppliers delivering the "same" component often in practice deliver slightly different products: different manufacturer, different manufacturing location, different composition or different batch. Each of these variants in principle needs its own passport, based on the data from the party that placed that specific product on the market.

What is and is not covered here

This topic is particularly relevant for purchasers and assemblers who source a component — a battery, a module, a component — from different sub-suppliers to spread supply risks or compare prices. This concerns how the passport handles that practice, not whether the passport is mandatory for the end product: the latter depends on the product category and when the obligation for that category takes effect, as described in or the product passport applies to your electronics.

What is important is the distinction between two situations that at first glance appear the same. One: the component itself must have its own passport, because it is placed on the market as a standalone product and falls under a mandatory category. Then for every supplier of that component it applies that they supply their own passport, and differences between suppliers are simply differences between products. Two: the component is a component in a larger end product, and the question is what data on that component ends up in the passport of the end product. Then the component is not the unit of the passport, but the assembled end product — and the role of the component supplier is comparable to that of a sub-supplier further down the chain, as also described in the question of whether a subcontractor must supply passport data. This section does not address which data exactly is needed — that is described in the data requested from an electronics supplier.

No fixed date yet, but a fixed route

When this obligation takes concrete effect is not yet established. The digital product passport for electronics and ICT equipment comes per sub-category, via delegated acts expected from 2027 onwards according to the ESPR work programme 2025-2030. As long as no delegated act has been published for a sub-category, no passport obligation applies for that category — and therefore no concrete obligation on how to deal with multiple suppliers of the same component. What is already established, however, is the framework from the ESPR itself: Article 10 of Regulation (EU) 2024/1781 describes the requirements a passport must meet, and Article 38 describes what obligations actors in the supply chain — including component suppliers — have in this regard. As soon as a delegated act is published for a sub-category, the exact date and exact specification will be stated here. More on how those delegated acts work is in what a delegated act is and why it is decisive, and the broader timeline is in when the passport becomes mandatory for electronics.

How this is tackled in practice

The first step is to determine whether the component itself is an independently passport-obligated product, or whether it is merely processed as a component in a final product. This determines who makes which passport. If the component is independently passport-obligated, then each supplier provides its own data for its own version of the component, and a separate passport is created per supplier — and sometimes per manufacturing location or batch. If the component is processed into a final product, then the next step is: request from each supplier the data needed to complete the passport of the final product, and keep that data separately per supplier, even if the components appear functionally identical. In practical terms, this often means that when switching suppliers, or when simultaneously using multiple suppliers for the same position in the production line, the passport of the final product moves with whoever supplied which component — comparable to the situation where the composition of a product varies per batch, as discussed in how the passport is completed if a product changes per batch. It is therefore advisable to establish in advance, when procuring from multiple suppliers for the same component, who supplies which data and at what time, something that fits well with the agreements that are established anyway in a purchase contract, see how the supply of passport data is established in a purchase contract. Once the data is in hand, it is wise to verify it for consistency between suppliers, as described in verifying a supplier's data for accuracy.

The legal basis: Articles 10, 29 and 38 ESPR

That a passport is linked to a specific product as placed on the market by a specific economic operator follows from Article 10 of Regulation (EU) 2024/1781, which describes the substantive requirements for the digital product passport. The obligations of actors earlier in the supply chain — such as component suppliers — to make the necessary data available are set out in Article 38 of that regulation. For components or products imported from outside the EU, the obligations for importers under Article 29 also apply, which becomes relevant once one of the suppliers is established outside the EU; this relates to the subject discussed in what the product passport means for imports from outside the European Union.

Those who already work with multiple suppliers for the same component may find it useful to document per supplier which data are available and which are still missing, so that work is ready as soon as the delegated act for the relevant subcategory is published.