what must I arrange for the passport if I change supplier

The passport follows the product, not the supplier

When switching aluminium suppliers, in most cases nothing changes in the passports that are already linked to products already placed on the market — those remain as they are, with the data of the original manufacturer or importer in them. What does require attention is everything that is newly placed on the market after the switch: for that new aluminium, a complete new passport must be created, built up from the data of the new supplier. So one passport is not "transferred" from the old to the new supplier — in practice a new passport line is added alongside (or after) the old one.

Who this applies to, and who it does not

This applies particularly to those who resell, process or supply aluminium under their own brand and change suppliers in the process — think of a profile manufacturer that switches to a different foundry, or an importer that brings in a new manufacturer outside the EU. It does not apply in the same way to those who are merely a distributor or trader: they generally pass on the responsibility for the content of the passport to whoever places the product on the EU market, as described under what obligations does a distributor or trader of aluminium have. It also applies differently to those who sell under their own brand, because there the brand owner often acts as the responsible party themselves, as explained under I sell aluminium under my own brand — what obligations do I get. Important to distinguish: a change of supplier is different from a change of production location within the same company — the latter affects the question of who is responsible for the passport if production takes place in multiple EU countries, which is a separate matter.

When this becomes relevant

The obligation to maintain a digital product passport applies from the moment the relevant product group of aluminium falls under the delegated act of the ESPR. For aluminium semi-finished products, that moment has not yet been determined: the delegated act is expected in 2027 according to the ESPR work plan 2025-2030, and the precise obligation date after that will be posted here as soon as that act is published. Until that time, there is no legal passport obligation in the event of a supplier change, but the practical questions — what data the new supplier must provide, how the data link proceeds — can already be prepared now, so that the switch does not delay once the obligation comes into force.

What can be arranged in practice when switching suppliers

As a first step, it is worthwhile to determine who fulfils the role of manufacturer or importer in the new situation, as that role determines who provides the data for the passport — that distinction is detailed under am I an importer or manufacturer under the ESPR. If the new supplier is outside the EU, then the question of who on behalf of that party takes on the obligations within the EU is relevant, as described under my manufacturer is outside the European Union — who arranges the product passport then. Following this is the practical part: the new supplier must provide the material and product data needed to compile a passport — think of composition, origin and the other elements that Article 10 of the ESPR makes mandatory. For alupas.eu, this means that data must be submitted and verified afresh for each new supplier, and the new passport receives its own QR data carrier that stands separately from earlier passports. If you work with multiple sub-suppliers simultaneously for the same product line — for example during a transition period in which the old and new supplier operate side by side — it is advisable to document clearly per batch which batch, which passport and which QR code belong together, so that no passport is linked to the wrong product. It is also useful to agree in advance who bears liability if something in the supplied data is incorrect, as this question arises more often with a supplier change than with a fixed, long-term relationship — more on this is discussed at who is liable if there is incorrect data in the product passport. If you supply aluminium to a brand owner instead of placing it directly on the market, you may also face your own division of tasks, as discussed in the question about responsibility in private-label supply.

The basis: Articles 38, 29 and 10 of the ESPR

That the passport is linked to the product and not to the supplier follows from Article 10 of the ESPR (Regulation (EU) 2024/1781), which sets out the requirements for the digital product passport — the passport contains product-related information that belongs to that specific product or batch. Article 38 of the ESPR describes the requirements for actors in the supply chain and makes clear that every party in the chain bears responsibilities for the information it supplies or passes on, which becomes relevant as soon as a new supplier enters that chain. For those sourcing aluminium from outside the EU, Article 29 of the ESPR is also relevant, which describes the obligations of importers — in a change to a new supplier outside the EU, those obligations shift accordingly to whoever acts as importer for that new supplier.

What to do now

When an upcoming or recently implemented supplier change is due, it is practical to first establish your own role (manufacturer, importer or distributor), then agree with the new supplier which data will be provided and when, and document that agreement before the first new product goes to market. For those who already have a passport compiled via alupas.eu, notifying a supplier change is the first step — the submission of the new data and the linkage to a new passport follow naturally from that process.

What this is based on

The regulation itself is on EUR-Lex. We refer per statement; you do not have to take our word for it.

What you must concretely do

What is expected of you

A supplier change is essentially a modification in the supply chain: the aluminium semi-finished product will henceforth come from a different manufacturer, foundry or importer, and the data that previously appeared in the product passport will no longer be correct as a matter of course. The ESPR approaches this from the perspective of the roles that different parties in the chain have, not from the change itself. This means that the question "what do I need to arrange" in practice breaks down into a few separate points.

Determine who now supplies the data

Article 38 of the ESPR (Regulation (EU) 2024/1781) describes what actors in the supply chain are expected to do when it comes to making available information needed for the product passport. With a new supplier, this practically means that it must be established again which party provides the source data: alloy composition, material origin, any recycling content, production process. For a company with 10 to 100 employees, this often amounts to designating a fixed contact point at the new supplier who is responsible for this data, and building in a moment — for example at the first order — when that data is requested and checked before it ends up in the passport.

Determining whether your own role changes

A supplier change can shift your own position in the chain. If you previously purchased aluminium from a European producer and switch to a manufacturer outside the EU, you may face different obligations: Article 29 of the ESPR (Regulation (EU) 2024/1781) describes what is expected of importers, and those obligations differ from those of a party that only resells within the EU. It is therefore worthwhile to review again with each change whether your own position is that of importer or manufacturer, especially when the new manufacturer is outside the European Union. For a mid-sized company, this is often not a legal exercise but a practical one: who will sign the customs documents in future, who appears first as an EU party in the chain, and who is therefore responsible for providing the passport data.

Ensuring the passport aligns with the new product

Article 10 of the ESPR (Regulation (EU) 2024/1781) describes the requirements that a digital product passport must meet, including that the information in the passport corresponds to the product to which it applies. A supplier change usually means different composition, different production data or different origin — even if the end product looks identical. For a company, this means that an existing passport cannot automatically be "transferred" to the product from the new supplier. It must be determined again whether it is a new passport or an update of an existing passport, depending on how substantial the change is.

Where things go wrong in practice

A few situations keep recurring in a supplier change.

The passport is not adjusted because the end product "looks the same". The alloy comes from a different foundry, but no one checks whether the composition or recycling percentage differs from what is stated in the existing passport. That is precisely the risk covered by Article 10: the data no longer correspond to the actual product.

The old supplier no longer provides the source data, but the new supplier is not yet set up to provide it. A gap arises between terminating one relationship and the other becoming operational, and during that period deliveries are sometimes made without anyone checking whether the passport is still accurate.

In a switch to a supplier outside the EU, the change of role is missed. The company continues as before, while its own role actually shifts to that of an importer — with different expectations regarding the provision and verification of data than in an intra-EU relationship.

In private label purchasing, it is assumed that the new supplier "will handle that passport business", without this being documented anywhere. If you supply aluminium to a brand owner or conversely you sell under your own brand, you run a real risk if the agreement was never put in writing.

No archive is kept of which passport belonged to which supplier and which delivery. With a change after a few years, it is then no longer possible to reconstruct which data came from whom, which becomes a problem as soon as uncertainty arises about who is liable in case of incorrect data.

What you can document now

A number of matters can be documented with little effort, and prevents a supplier switch from leading to confusion later:

Contact point at the new supplier for the passport data: name, function, and the arrangement how and when the data are supplied.
Overview of own role per supplier: manufacturer, importer or reseller only, with a brief justification why. This aligns with the question who within own organisation is responsible for the product passport.
Date of the switch: from which delivery the new supplier applies, and which passport belongs to which batch.
Comparison old/new passport: a brief check whether composition, origin or recycling content differs, and whether this requires an update or a new passport.
Written agreement on who compiles and hosts the passport when working with a private label or own brand, including who supplies which data.
Archive of previous passports and associated supplier data, so that after a switch it can still be traced which passport belonged to which delivery and which supplier.

For companies that work with multiple suppliers at the same time, or that themselves produce in multiple locations within the EU, it is advisable to manage this overview centrally rather than per location separately — see also the situation in which a company produces in multiple EU countries. A fixed template for documenting supplier switches prevents these points from having to be reinvented at every switch.

This is not legal advice. This page provides general information on the legislation that this platform covers. 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 incorrect? Let us know — corrections are prioritised.