A supplier is, in short, the party that makes a product with an aluminium component available on the EU market or makes it purchasable to the end user. It is not a separate legal term with its own, clearly defined definition, but a collective term used in practice for the party responsible for displaying and keeping the product passport accessible at the moment of supply: in the shop, on a website or in a quotation process.
The regulation itself works with a fixed set of roles in the chain, such as manufacturer, importer, authorised representative and distributor. Which of these roles bears the obligation to ensure the passport exists and is displayed in a specific case depends on who places the product on the market under their own name or makes it available. In practice, 'supplier' is often the role closest to the end user at the moment of the transaction, but the precise definition varies per situation and is set out in the official text, not in a simple rule of thumb.
Why this role matters
If you sell or resell aluminium profiles, castings or packaging, it is useful to know which role you are in at the moment a customer buys or orders the product. Not because the term itself creates a separate obligation, but because the role determines who must be able to display the passport at that moment, for example via the QR code on the product or packaging. A manufacturer that supplies directly to the end user often fulfils that role itself. A trader that purchases and resells can also take on such a role, depending on how the product reaches the customer.
For companies that are only a component supplier within a larger chain — for example, a profile manufacturer that supplies to a window frame builder — the question is different from that for a company that sells directly to the building supply market or end customer. Who in your own chain actually fulfils that role is something you would best determine per product line and per sales channel.
How the roles in the chain relate to each other
The roles of manufacturer, importer, distributor and supplier do not exclude each other and can in practice also overlap. A company that manufactures aluminium profiles itself and sells directly to the end customer is at the same time a manufacturer and the party that displays the passport at the point of sale. An importer that sources aluminium components from outside the EU and resells them in the Netherlands can fulfil both the role of importer and that of supplier, depending on the sales channel.
This kind of overlap is precisely why it is useful to have a clear picture of your own position in the chain before you speak to a software supplier or partner about setting up the passport. Those who do not yet have a clear overview of this can get a first picture of their own position by answering a few questions before taking further steps.
What this could mean for your business
For an installation company that purchases and processes aluminium window frame profiles, the question is mainly relevant at the moment the final product is offered to a private or business customer: who ensures that the passport is accessible? For an office manager who purchases packaging aluminium for internal use, the question is usually less relevant, because there is no question of offering it again to another customer.
The key point is that the term 'supplier' does not add a separate, heavier obligation on top of what the regulation already stipulates for manufacturers, importers and distributors. Rather, it is a practical designation of who, at the moment of the transaction, is actually responsible for the accessibility of the passport. A clear overview of the concepts used in the regulation, including how they relate to each other, can be found in the knowledge base with explanations per subject.
Where you look this up
Because the precise delimitation of roles in the chain is derived directly from the official text of the regulation, it is advisable to consult the source text or involve a lawyer if you are uncertain about your own position, especially if your business operates in multiple links of the chain at the same time. Frequently asked questions about how roles are filled in practice are compiled on the page with answers to questions that entrepreneurs often ask.
If you want to know how alupas.eu compiles the data for the passport and where that information comes from, you can read about it on the page which explains how the information is created. That gives you a good picture of what is practically asked of you, apart from the precise legal role you hold in the chain.
Would you like to get a first, non-binding picture of where you stand in your own situation? The free quick-scan gives an indication within a few minutes, without requiring an account.