How do I verify that my supplier's data is correct?

What you must concretely do

What is expected of you

Complying with the test, measurement and calculation methods in Article 39

Article 39 of the ESPR (Regulation (EU) 2024/1781) provides that the data in a product passport shall be established in accordance with established test, measurement and calculation methods. These methods shall be developed per product group in delegated acts — for steel this has not yet been published. In practical terms, for a company with 10 to 100 employees, this means that a data point such as the recycled content or a CO2 value is not simply a figure that a supplier passes on: there must be a method behind that figure by which it has been determined. Those receiving data can therefore ask on the basis of which method a figure has been calculated, even if a definitive method for steel has not yet been established.

Preventing circumvention and degradation of performance

Article 40 of the ESPR concerns the prevention of circumvention and degradation of performance: it is not the intention that a product shows different properties during a test than during normal use, or that a manufacturer allows the performance of a product to deteriorate once it has been approved or certified. For a metal processor or construction company that purchases semi-finished products, this means that a data point that has been established at one point in time — for example, at the first delivery of an alloy — does not automatically continue to apply to subsequent deliveries. The underlying thinking of Article 40 is that the actual, used performance corresponds to the stated performance, and this is something that a customer must remain vigilant about in practice, even with a fixed supplier.

Verifying for yourself that the supplied data is plausible

There is nowhere in the ESPR an obligation for the recipient to verify or certify supplier data themselves. What does follow from it — via the methods of Article 39 and the starting point of Article 40 that performance must be real — is that a company has an interest in being able to assess supplied data: does the value correspond to what is customary for this type of steel, can the origin of the data be traced, and is it clear who has supplied which part of the passport. For a company with 10 to 100 employees, this is usually not a separate control team, but a standard step when receiving a delivery: a quick look at the supporting documentation alongside the invoice and delivery note.

Where things go wrong in practice

A supplier provides a figure without supporting documentation. A percentage of recycled material arrives, but not the calculation method on which it is based. Without that information, it is not possible to see whether the figure has been determined according to a method that complies with Article 39, or whether it is an estimate.

Data does not change, while the production process has been modified. A supplier changes, for example, the melting route or the percentage of scrap, but the passport remains unchanged. This touches precisely on what Article 40 seeks to prevent: that an once established performance becomes disconnected from the actual, current production.

Data from different suppliers are combined without explanation. In the case of a composite semi-finished product, figures from multiple batches may appear side by side without it being clear which part comes from whom. For those dealing with this, further information on the approach to this is available at how do I combine data from different suppliers in one passport.

Data from a country outside the EU are difficult to verify. When importing steel from outside the Union, there is often no direct way to verify the underlying measurement method; background information on this is available at how do I know if data from my foreign supplier is correct.

A supplier refuses to provide supporting documentation by invoking an NDA. Confidentiality and the provision of substantiated data are sometimes set against each other, while with the right agreements a workable form can be found for this — see can I agree on an NDA and still comply with the passport.

What you can document

• The requested supporting documentation per data point. Which values are requested and which method or standard applies to them — an overview of this is available at Which data must I request from my steel supplier?
• A contractual agreement on the provision and updating of data. Recording when data is delivered, in what form, and what happens if the production process changes — how this can be included in a purchase contract is set out in How do I record the delivery of passport data in my purchasing contract?
• A fixed procedure for what to do in case of missing or incomplete data, including the point at which this is followed up with the supplier — see My supplier does not provide the data — what can I do?
• An internal log of data received per delivery, with date, supplier and the corresponding evidence, so that data can be traced back later
• A short internal checklist for whoever enters the data, containing the question of whether a value is plausible given previous deliveries from the same supplier or the same type of steel