What obligations does a distributor or trader of furniture have?
Check and pass on, do not draw up yourself
A distributor or trader of furniture checks that a product meets the requirements before it is offered for sale, but does not draw up the digital product passport itself. That obligation rests with the manufacturer or importer, who supplies the data with which the passport is compiled. The role of the distributor is one of checking and passing on: verifying that the furniture bears the required marking, that the data carrier (the QR code) is present and readable, and that the accompanying documentation is correct. Article 30 of the ESPR (Regulation (EU) 2024/1781) sets out these obligations for distributors. Any trader who places furniture on the market under its own name or brand, or substantially modifies the product before it is sold, no longer falls under the lighter distributor regime: Article 31 of the ESPR provides that such a party is then treated as a manufacturer, with the corresponding, heavier obligations.
Who this applies to, and who it does not
These obligations apply to anyone who, further down the supply chain after the manufacturer or importer, offers a furniture product on the market without being a manufacturer or importer themselves: wholesalers, retailers, project furnishers who resell ready-made furniture, and comparable intermediaries. They do not apply to the end user who purchases furniture for their own use, nor to the manufacturer or importer themselves — different, more extensive obligations apply to them, which are set out separately in the ESPR. The boundary between "distributor" and "manufacturer" is not simply a matter of who makes the furniture: as soon as a trader sells a product under its own brand or makes a substantial change to it, that party moves into the heavier category, regardless of whether an original manufacturer also exists. This distinction is relevant for those trading in white-label furniture or having custom work done by a third party.
No fixed entry date yet
No date has yet been set for when these obligations for furniture will come into effect. The ESPR itself is the framework; the product-specific requirements for furniture — including the date on which the digital product passport and the associated obligations for distributors become mandatory — will be set out in a separate delegated act. According to the European Commission's work plan for 2025-2030, the delegated act for furniture is expected in 2028, but this is a planning projection and not a set date. Until that act is published and the transition period it contains has elapsed, there are no obligations for furniture on the basis of these articles. As soon as more is known about when this will apply to furniture, it will be updated here.
How a distributor can put this into practice
The first step is to check with the supplier — the manufacturer or importer — whether the furniture bears the required marking and has a functioning data carrier, and whether the underlying documentation is complete. It is then important that storage and transport do not damage the marking and QR code or render it unreadable, as this too falls within the distributor's duty of care. If there is any doubt about the conformity of a product — for example a missing or non-functioning QR code, or documentation that does not match the furniture supplied — it makes sense not to offer the product for sale until this has been clarified, and to inform the manufacturer or importer accordingly. If there is a situation involving a potential risk, notification to the market surveillance authority is also warranted. A trader should also keep records of what information was received and from whom, so that this can be provided to a supervisor if required. Anyone considering selling furniture under their own brand or adapting it before it reaches the shop or project should check in advance whether this entails manufacturer status, with all the associated obligations.
Where this follows from: articles 30 and 31 of the ESPR
This breakdown of obligations comes from the chapter of the ESPR (Regulation (EU) 2024/1781) on economic operators. Article 30 describes the obligations of distributors: checking of marking and documentation, careful handling of storage and transport, not offering where there is reasonable doubt, and cooperation with market surveillance. Article 31 sets out when a distributor or importer is to be regarded as a manufacturer for the purposes of the regulation, namely when selling under its own name or brand or when making a substantial modification to the product. The product-specific implementation for furniture — including the starting point — follows from a delegated act yet to be published under this regulation.
For those already trading in furniture, it is best to map out in advance which suppliers furniture comes from and whether agreements will be needed in the long term on the provision of passport data and a functioning data carrier. For the current status of the delegated act and the exact date of application, the official ESPR text and the work plan of the European Commission are the source to follow; this page will be updated as soon as there is news on this.
This is based on
The regulation itself is available on EUR-Lex. We refer per statement; you do not need to believe us.
What you concretely have to do
What is expected of you
A distributor or dealer is in most cases the party that resells furniture without having manufactured or imported it from a country outside the EU — think of the wholesaler, the retail chain or the project furnisher that purchases from a manufacturer or importer within the EU. The ESPR (Regulation (EU) 2024/1781) imposes on these parties in articles 30 and 31 a number of obligations that are lighter than those of manufacturer or importer, but not optional. Anyone in doubt about which role their own business falls under reads more about it on who is responsible for the product passport for furniture?.
Check whether the product passport is present
Before furniture is offered, the distributor or dealer is expected to check whether a digital product passport is present and whether the associated QR data carrier has been affixed to or attached to the product. For a company with 10 to 100 employees, this usually means that the purchasing department adds a check point to the existing purchasing process: when receiving a new collection, it is verified that the passport matches the article, not just that something has been attached.
Check whether mandatory labelling and conformity marking are present
In addition to the passport itself, these parties are expected to check whether the mandatory markings and statements present that belong to the product are present. This is not a substantive assessment of the correctness of the data, but a visibility check: is it there, and is it readable.
Do not supply if anything is visibly missing
When a distributor or dealer has reason to believe that a product does not meet the requirements, it is expected that the product is not placed on the market until this is remedied. This directly affects planning: a delivery that is stopped at the last moment because a passport is missing has consequences for a store or project schedule. Companies that sell furniture themselves under their own brand are assigned a different role — this is detailed on I sell furniture under my own brand — what obligations do I get?.
Inform the supervisory authority of a risk
If a distributor or dealer suspects that a product is not in conformity, it is expected that the relevant market participant and the supervisory authority are informed of this. This requires an internal point of contact: someone within the company who knows who this should be reported to and how, rather than the notification getting lost somewhere between purchasing and customer service.
Cooperate with the supervisory authority
At the request of a supervisory authority, the distributor or dealer is expected to cooperate, among other things by providing relevant information and documentation. For a mid-sized company, this means that it must be clear where this documentation is located and who can provide it — often it is actually held by the manufacturer or importer, and then the question is how quickly that can be consulted.
Pass on information in the chain
When a distributor or dealer themselves also passes on as an intermediate party — for example to another dealer or to a marketplace — it is expected that relevant information about the product is passed on. In the case of sales via a platform, this plays its own role, which is explained further on what does the product passport mean if I sell furniture via an online marketplace?.
Where things go wrong in practice
A first situation is the collection that comes in via multiple intermediate dealers, where no one any longer knows exactly who the original manufacturer or importer is. The passport is missing, and the distributor who is last in the chain is the first to be addressed without it being clear where the responsibility for the source data lies.
A second situation is the assumption that "the supplier will have arranged this". There is no active checking whether the product passport and QR data carrier are present, so a missing passport only becomes apparent during an inspection or complaint, rather than upon receipt of the goods.
A third situation arises when a company makes its own modifications to a purchased product, for example by replacing a component or adapting the upholstery for a project client. This can change the company's role from distributor to manufacturer, with a completely different set of obligations — see do I become a manufacturer if I have an existing piece of furniture adapted or refined?.
A fourth situation is the manufacturer located outside the EU and where the importer in the supply chain is not clearly designated. The distributor then assumes that "someone else" has already had the product passport drawn up, when in fact it still needs to be done — this often occurs with my manufacturer is located outside the European Union — who arranges the product passport then?.
A fifth situation is uncertainty about incorrect data: a distributor that passes on the product passport unchanged does not think itself liable if the content is inaccurate. Who is responsible for this is more nuanced than might be thought — see who is liable for incorrect data from a supplier in the passport.
What you can put in order now
- A fixed checkpoint in the procurement process where it is recorded whether the product passport and QR data carrier have been checked per article upon receipt.
- An internal arrangement about who within the company reports a suspicion of non-conformity, and to whom — including contact details of the relevant supervisory authority.
- An overview per supplier or manufacturer of who the contact point is for documentation, so that if a supervisory authority makes a request, it is quickly clear where the underlying data comes from.
- A list of agreements with suppliers about the time at which the product passport is delivered — before delivery, not afterwards.
- A log of deliveries that have been withheld or delayed due to a missing or incomplete product passport, with the final resolution.
- When reselling to other parties: a fixed procedure for passing on passport data, so that this information is not lost between links in the supply chain.
For companies that are not yet certain whether they will be classified as a distributor, importer or manufacturer, this is often the first question that needs to be answered before any of these arrangements can meaningfully be documented — see am I an importer or manufacturer according to the ESPR?.
This is not legal advice. This page provides general information about the legislation that this platform concerns. 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, reviewed by a human on 2026-08-22. Is something wrong? Let us know — corrections take priority.