can I use my existing product database for the product passport
Yes, as a source — but not as the passport itself
An existing product database can usually serve as a source for the data that ends up in a digital product passport, but the database itself is not a product passport. The product passport is a specific data format that is linked to a unique carrier (usually a QR code) per product or product model, with fixed requirements for structure, accessibility and coupling with other systems such as the EU registry. The information that is already in an ERP system, PIM system or Excel list — materials, dimensions, article numbers, supplier, composition — is exactly the kind of data that will have to go into a passport later. That data does not therefore need to be collected again, but it does need to be transferred to the correct format and linked to the correct carrier.
Which data this works for, and which it does not
Data that is fixed per product or product model — such as material composition, origin, dimensions, warranty information or maintenance instructions — lend themselves well to reuse from an existing database. This data is part of what Article 9 of the ESPR (Regulation (EU) 2024/1781) describes as the core of the digital product passport: information that must be accessible per product via a data carrier. What an existing database often does not provide is the technical structure prescribed by Article 10 of the ESPR: a unique product identification number, a link with the registry, and a format that can be read uniformly by market participants, competent authorities and consumers. An internal database is usually designed for the company's own operations — inventory management, order processing — and not for external, standardised reading as required by Article 11 of the ESPR for the technical functioning of the passport. That is the difference between "the data is already there" and "the passport is already there": the first is often true, the second rarely is.
When this becomes relevant
The question of whether an existing database is suitable becomes concrete only once the obligation for furniture comes into effect, and that moment is not yet fixed. As also explained on the page on when the product passport becomes mandatory for furniture the delegated act for furniture has not yet been published; it is only then that it will determine exactly which data is mandatory and what format it should have. Until then, there is no legal obligation to maintain a passport, but that does not mean that waiting is the only option. What is already established until then is the general structure of the ESPR itself — Articles 9, 10 and 11 — which sets out the framework within which the delegated act for furniture will be developed.
How to approach this in practice
The first step is to check which data already exists and where: material composition, origin, dimensions, and any existing certificates or test reports. Much of that information is often scattered across different systems — an ERP for inventory, a PIM for product information, loose documents for certificates. A second step is to assess whether that data is consistent and up-to-date at product model level, because the passport requires unambiguous information per product, not per order or per batch. A third step is to check what data is missing; these are often precisely the data specifically requested for the passport, such as repair or disassembly information, which is usually not standard in a sales or inventory system. For anyone who wants to get started with this now, even without the exact requirements being fixed, the page on describes what you can do now while the rules are not yet final a number of preparatory steps that can be taken without risk. For an overview of the approach in sequence, from data collection to placing the data carrier, the page on the digital product passport step by step a logical follow-up.
A key point with collections that have many variants — colours, upholstery, leg types — is that an existing database often manages those variants as separate SKUs without a shared foundation. The passport specifically calls for a clear link between what is shared within a collection and what differs per variant, something that receives dedicated attention on the page about creating passports for a collection with many colour and fabric variants.
The legal basis: Articles 9, 10 and 11 of the ESPR
Article 9 of the ESPR (Regulation (EU) 2024/1781) establishes that a product with a digital passport must be provided with a data carrier that makes information about that product accessible. Article 10 describes the substantive requirements that such information must meet, including the link to a unique identification number and the registration register. Article 11 addresses technical operation: how the passport must be readable and exchangeable between different parties in the supply chain. Together, these articles establish that a product passport is not merely a database of product information, but a specifically structured layer on top of it — built on data that often already exists, but supplemented and structured according to requirements that will be established per product group.
Anyone who now wishes to check whether their own furniture will be subject to this obligation can do so on the page about whether the digital product passport applies to specific furniture, and anyone who first wants to understand what a product passport substantively is will find that on the page about what a digital product passport for furniture is. The most practical step now is: to inventory and organise existing product data per product model, so that supplementation later is limited to what is truly still missing.
This is based on
- Regulation (EU) 2024/1781 (ESPR), Article 11 (technical design and operation of the digital product passport)
- Regulation (EU) 2024/1781 (ESPR), article 10 (requirements for the digital product passport)
- Regulation (EU) 2024/1781 (ESPR), Article 9 (digital product passport)
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
Many companies with 10 to 100 employees already have a product database: an ERP system, a PIM system, or simply an extensive Excel file with article numbers, materials, dimensions and supplier data. The question is not whether that database is useful, but whether the data in it meets what the ESPR expects from a digital product passport. These are two different things.
The content must conform to what the delegated act requires
Article 9 of the ESPR (Regulation (EU) 2024/1781) describes the digital product passport as a collection of product information that is accessible via a data carrier. Which information precisely must be included will be set out per product group in a delegated act. For furniture, this has not yet been published. In practical terms, this means that an existing database often already contains part of the requested information — material composition, origin, dimensions — but rarely everything. Repair information, recycling instructions or data on recyclability are not typically standard in an ERP system that has been set up for inventory management and invoicing.
The data must be structurally linkable to a data carrier
Article 11 of the ESPR sets requirements for technical design: the passport must be accessible via a data carrier (such as a QR code) and the data must be provided in a structured, machine-readable manner. A database that is used only internally and is not set up to establish a unique, lasting link per product specimen or model with a data carrier does not automatically meet this requirement. For a company of this size, this typically means that an additional layer is needed between the existing database and the outside world: a system that retrieves the correct data from the database, puts it in the correct format, and links it to a QR code that remains accessible for ten years.
The accessibility must meet the requirements of Article 10
Article 10 of the ESPR concerns who may access which data and how long such data must remain available. An internal database is typically not designed for public or partially public accessibility, let alone for a retention period that is independent of whether the company still exists. This requires a separate system alongside the existing database, not a replacement for it.
Where things go wrong in practice
A manufacturer assumes that because all technical specifications are already in the ERP system, the passport will 'simply roll out' from it. In practice, the very fields that the ESPR is likely to require are missing, such as repair and disassembly information, and these must still be added manually.
An importer works with a database from a manufacturer in a country outside the EU and assumes that data can be used one-to-one. The source data is often not in the structure or language required, and the importer, as a market actor in the EU, has its own responsibility for the accuracy of the data that ultimately appears in the passport.
A project furnisher maintains its own article database per customer project, but it is not linked to an individual data carrier per product. Upon inspection, it turns out that there is no direct, stable link between a sold piece of furniture and the corresponding passport data.
A company updates its own database regularly, for example when materials change, but forgets that the passport of already sold products no longer matches the physical product. The internal database is a 'living' document; the passport must instead be a reliable record at the point of sale.
A company with many colour and fabric variants manages those variants as a separate field within a single product code, whereas the passport may require different data per variant — consider a different material percentage with a different fabric choice. Those dealing with this will find more about this specific complication at how do I create passports for a furniture collection with many colour and fabric variants.
What you can put in order now
- An overview of which data already exist in the current database, and which of these are likely relevant for a product passport — based on the direction given by Articles 9 and 10 of the ESPR (Regulation (EU) 2024/1781), even though the exact list per product category is not yet fixed.
- A note on the source and reliability of each piece of data: whether it was determined in-house or taken over from a supplier or manufacturer elsewhere in the chain.
- A process for tracking changes to product data, so that it is clear which version of the data belongs to which sold product.
- Agreements with suppliers on which data they provide and in what format, especially when the internal database depends on their input.
- An overview of product variants and the data that may differ per variant, particularly for colour and fabric versions.
Those who wish to structure this now, even before the delegated act is in place, will find an approach in what can I already do while the rules are not yet definitive. And for those who want to know how this inventory fits into the rest of the process, an overview is provided in how do I tackle the product passport for furniture step by step.
An existing product database is therefore rarely worthless, but also rarely sufficient on its own. In most cases, it forms a useful starting point: the basic data are there, the structure and the link to a data carrier usually are not. It is wise to assess these two things separately — what data already exist, and what is still needed to turn that data into a passport.
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, checked by a human on 2026-09-05. Is something not right? Let us know — corrections take priority.