how do I know if data from my foreign supplier is correct

What you must concretely do

A steel trader who purchases profiles or sheet material from a producer outside the EU receives data that the trader itself has not been involved in: no visibility into the melt, the rolling mill or the laboratory where the tests were carried out. Yet that same trader, at the moment they act as an importer, becomes the one responsible for what is in the passport. This is the core of the question: trusting data on paper is different from being able to demonstrate that it is correct.

What is expected of you

Checking that the passport is present and complete

Article 29 of the ESPR (Regulation (EU) 2024/1781) describes the obligations of importers, and this includes checking whether the product is accompanied by the required digital product passport and whether that passport contains the data required by the applicable rules. For a company with 10 to 100 employees, this means in practice that there is someone — not necessarily a separate function, often the purchasing officer or the quality officer — who checks with each shipment whether the passport is present and whether the fields are filled in that apply to that type of steel product. Which fields exactly apply is described on the page on which data you must request from your steel supplier.

Not placing on the market products known not to comply

The same provision also means that an importer who knows or can reasonably suspect that a product does not meet the requirements must not put it on the market until it is compliant. This requires a certain level of vigilance: if a passport is evidently incomplete, or if figures for composition or mechanical properties do not match what is customary for the type of steel, "we received the passport" is not automatically sufficient.

Testing, measuring and calculating according to prescribed methods

Article 39 of the ESPR addresses the methods by which product properties are tested, measured or calculated. For an importer who does not test themselves, this mainly means that it can be checked whether the supplier has worked according to the method prescribed for that product characteristic, rather than using their own or a different test method. In practice this is difficult to assess without the supplier providing information about it — hence the importance of recording which method was used, not just what the outcome was.

Taking customs controls into account at import

Article 15 of the ESPR stipulates that customs authorities may check upon entry of products from third countries whether the digital product passport is present and accessible. For an importer, this means that border delays are a real consequence of a passport that is incorrect or not retrievable, regardless of what further controls may occur later in the supply chain. What this specifically means for the import of steel is set out on the page on import of steel from outside the European Union.

Guarding against circumvention and degradation of performance

Article 40 of the ESPR is aimed at preventing products from being designed, tested or reported in such a way that their actual performance appears more favourable than it is, or that rules are circumvented. For the practice of a trading enterprise, this translates primarily into vigilance: data that systematically fall just within a standard, or test results that are strikingly favourable compared to similar products, are not proof of fraud, but they are a reason to ask further questions.

Where things go wrong in practice

A supplier delivers a passport with data that have been taken from an older certificate of another party, without it being clear whether those data belong to the current batch. Nobody on this side of the border notices this, because the passport looks complete.

An importer receives test results, but not the indication of which test method was used. Upon inspection, the method used turns out not to be the method prescribed for that characteristic under Article 39 of the ESPR, whereas the result seemed plausible at first sight.

With a shipment from a third country, the passport is present, but not retrievable at the time of customs control as referred to in Article 15 of the ESPR — the QR code refers to a server that does not respond at that time. The delay that results from this is not caused by incorrect data, but by a technical problem that nobody had tested.

A trading enterprise purchases the same steel type from two manufacturers in different countries and combines the batches into one delivery to the customer. The passports of both manufacturers use slightly different units or rounding, which leads to a discrepancy when combining that nobody had noticed. How this combination can be done carefully is set out on the page on combining data from multiple suppliers.

An importer relies on the reputation of the supplier and omits substantive inspection of the passport, because 'that supplier has been delivering good work for years'. Reputation says something about the likelihood of errors, but nothing about what is found in a concrete inspection.

What you can document

• A fixed procedure in which it is checked for each shipment whether the passport is present and complete, using a fixed checklist per product group.
• An overview of which test method was used for which piece of data, separate from the result itself, so that it can be traced later whether Article 39 of the ESPR was followed.
• Correspondence with the supplier in which it has been established who is responsible for the accuracy of which piece of data — a good time to arrange this is when drawing up the purchase contract, as described on the page on agreements on the delivery of passport data in the purchase contract.
• A fixed sample inspection, for example by comparing data from the passport with an independent certificate or test report, as set out on the page on checking data for accuracy.
• A log of customs controls and their outcome, so that a pattern of problems with a specific supplier or route becomes visible before it leads to repeated delays.