There is no fixed deadline for gathering supplier data anywhere in the regulation. What can be said is this: companies that have already gone through this process almost universally report that it takes longer than their initial estimate. Not because the question is complicated, but because the answers are scattered across multiple parties who are not accustomed to providing that information quickly or consistently.
The throughput time depends heavily on three things: how many suppliers are in your chain, whether those suppliers already keep their data digitally and in a structured way, and whether you yourself have already documented which data is needed. With a single fixed supplier with well-documented assortment, this can be completed within a few weeks. With a procurement chain with multiple links, some of which are outside the EU, this in practice stretches into months.
Why this process often takes longer than expected
Most of the delay does not occur in drawing up the passport itself, but in the step before: tracking down the correct data from the right person within a supply chain. A request lands with a sales department that does not itself control the technical specifications, gets forwarded to quality control, and arrives there with someone who has never received this question before. Each handover costs time, and with multiple suppliers at once, that adds up.
A second delaying factor is unclear understanding of exactly what is being asked. Suppliers being asked for this data for the first time often ask questions in return: why it is needed, in what format, and whether this also applies to competitors. A clear, unambiguous request saves multiple rounds of back-and-forth emails.
Where the process gets stuck in practice
Three bottlenecks come up most often. First, missing or outdated certificates: a supplier has an alloy composition ready, but the associated certificate cannot be found or belongs to an older batch. Second, suppliers outside the EU who are not familiar with the request and view the urgency differently than a European buyer. Third, internal systems that contain data but not in a form that can be used without manual transcription.
None of these bottlenecks is unsolvable, but they are the reason why a process that looks simple on paper costs several extra weeks in practice. Those who know this before the process begins can account for it in their planning.
What makes the throughput time shorter
It helps to establish in advance which data is needed, in what format, and from whom. A standard request that you send to every supplier at the same time works faster than separate requests afterwards. It is also worthwhile to make this request part of the conversation with suppliers now, even though the obligation is not yet fixed: those who already know which data is missing will not have to wait for it later. In the knowledge base sorted by topic each situation explains which data is typically requested and why.
It is also the reason this element is often included in the contract or purchasing terms with a supplier: those who contractually establish that data must be available on request avoid this conversation only arising when time is already tight.
The relationship with the obligation date
The obligation itself has not yet taken effect. The delegated act with the precise requirements is expected in 2027 according to the current work plan of the European Commission, and the obligation itself is expected around 2029. Both dates are not yet fixed. That is precisely the reason not to delay collecting supplier data until the last moment: a process that takes weeks to months is better started now than only after the exact requirements are known.
Would you like an indication of where your own chain currently stands? With a few questions you immediately see an indication of which data you probably already have and which are still missing. How that picture is built up is explained on the page about how the information is compiled, and frequently asked questions on this subject are collected on the overview with frequently asked questions.
If you are uncertain whether this is relevant for your own situation, it is advisable to go through the free quick-scan or to read through the topics in the knowledge base at leisure. For the precise explanation of the obligation itself, the official text on EUR-Lex or the advice of a lawyer remains the starting point.