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

Ask about the measurement method, not just the figure

You cannot obtain complete certainty about the accuracy of a figure supplied by a supplier by looking at the figure itself, but by examining how that figure was obtained. The ESPR does not regulate this as an instruction for procurement control between undertakings, but as a framework in which test, measurement and calculation methods must be reliable, accurate and reproducible (Article 39), and in which a product must not be designed in such a way that it performs differently in a test than in normal use, or that performance deteriorates undesirably during use (Article 40). Whoever receives data from a supplier for a digital product passport may therefore ask which method was used and whether that method meets those principles — this is different from being able to determine for oneself whether the figure is correct.

This is about methods, not audits

Articles 39 and 40 ESPR are directed at the way the European Commission establishes test methods for product groups, and at preventing manufacturers from arranging products or software in such a way that test results are more favourable than actual performance. This indirectly affects the reliability of data that ultimately appear in a product passport, because if the underlying measurement is sound, the likelihood that the value is correct is greater. What this is not about: an obligation for a purchaser to conduct laboratory testing itself, a quality mark, or a legally prescribed procurement checklist. These articles also contain nothing about how a specific dispute between purchaser and supplier over an incorrect value is settled — that is a different matter from the methods that Articles 39 and 40 address.

The date for aluminium is not yet fixed

Articles 39 and 40 are part of the ESPR itself and form the general framework. The specific test, measurement and calculation methods that will apply per product group — including for aluminium semi-finished products — are established separately for each product group. This has not yet been done for aluminium and no date for this has been set. What is established is the principle in Article 39 that such methods, once they exist, must meet demonstrable reliability and reproducibility, and the principle in Article 40 that circumvention and artificial performance deterioration are prevented. Until product-specific rules exist, there is no mandatory testing framework for aluminium based on these two articles — however, a supplier can already work voluntarily according to recognised standards and methods, and this is something that can be asked about.

How to approach this in practice

In practice, whoever checks whether supplier data are correct does so best in a number of steps. First: do not ask only for the value (for example a percentage of recycled material or a mechanical property), but also for the method by which that value was determined — which standard, which test, which calculation. Next: check whether that is a recognised, standardised method, or an internal method of the supplier itself; that distinction is precisely what Article 39 points to when it comes to reliability. Then: watch for signals that a product performs differently under test conditions than under normal conditions of use — that is the essence of what Article 40 seeks to prevent. It is also useful to ask whether performance may change over time, for example through software modifications to packaging components with electronic functions, without a clear technical reason for this; this also touches on the principle of Article 40. Finally: keep the evidence that a supplier provides. For a digital product passport, it is not only the value that matters, but also its origin and substantiation, and it is useful to keep that documentation together with the passport so that it can later, once a product-specific method has been established, easily be checked.

The basis: Articles 39 and 40 ESPR

Article 39 of Regulation (EU) 2024/1781 (ESPR) provides the basis for establishing test, measurement and calculation methods that must be reliable, accurate and reproducible and that take into account generally recognised methods. Article 40 of the same regulation addresses the prevention of circumvention — a design that changes performance once a product is tested — and the prevention of artificial degradation of performance during normal use. Together, both articles form the methodological foundation on which product-specific requirements, including those for aluminium, will subsequently be built.

Those who are already working with suppliers can thus begin right away by asking about the method used and its justification, and retaining that documentation. Once a product-specific regulation is established for aluminium semi-finished products, this page will be supplemented with which methods specifically apply and from which date.