must I have the CO2 footprint of my piece of furniture calculated for the passport

Not yet, as long as product requirements for furniture have not been established

A CO2 footprint will only appear in the product passport of a piece of furniture if the product-specific rules require it, and those rules do not yet exist for furniture. The ESPR itself does not directly mandate the calculation of a CO2 footprint; the regulation provides the framework within which, for each product group, information and performance requirements are laid down, including the question of whether a climate-related indicator such as the CO2 footprint becomes mandatory. For furniture, that implementation still needs to take place. Until then, there is no legal basis to regard a CO2 calculation as a mandatory part of the passport.

For which furniture this becomes relevant, and for which it does not

The question of whether a CO2 footprint becomes mandatory will only apply in the future to product groups for which this is explicitly included in a delegated act. Not every product within the ESPR receives the same requirements: the regulation works with tailor-made rules per product group, laid down via the ecodesign requirements and information requirements in articles 5 to 7 of the ESPR (Regulation (EU) 2024/1781). For furniture, that implementation does not yet exist. This means that a manufacturer or importer preparing a passport now does not need to reserve a CO2 figure because "it will come anyway" — that has not yet been established, and the form in which it may eventually come (a single figure, a range, a mandatory calculation method) is equally uncertain. This distinction is particularly relevant alongside other passport data that are already being concretely filled in, such as what data will be included in the product passport for furniture on the basis of the general structure in article 10.

When this will apply is not yet established

There is no fixed date on which a CO2 footprint for furniture becomes mandatory, because the delegated act with product requirements for furniture has not yet been published. According to the ESPR work plan 2025-2030, that act is expected around 2028, but that is a schedule and not an established obligation — the actual content and date of application will only become clear once the text is published. Until then, no obligation applies to furniture to calculate or report a CO2 footprint, simply because the legal basis for it is lacking. Once the delegated act for furniture is known, this article will be updated with the date stated in it.

What concretely needs to be done now

For those preparing the passport now, it is practical to focus on data that is already fixed or expected in the short term, rather than spending time on a CO2 calculation that has no legal basis yet. Concretely, this means, in the order in which it is usually tackled:

First get the basic data in order that is almost certain to become part of the passport, such as material composition. Those who need to record this for each part of a piece of furniture — the frame, the upholstery, the fasteners — will find this information at record materials per part of a piece of furniture. After that, it is useful to look at data that relates to measurement, such as emission classes or contents of certain substances, and to check according to which method measurement must be performed once that becomes relevant — this touches on article 39 of the ESPR, which establishes the frameworks for test, measurement and calculation methods once a product group receives specific requirements.

If you want to track climate data now — for example because a customer, contracting authority or your own sustainability policy requires it — you can certainly do so, but that is then your own choice or a contractual agreement, not an ESPR obligation. It is advisable to document such a calculation separately and not automatically align it with the legally required product passport, because the method and scope may still change when the official rules do appear. A calculation that is now made on your own initiative may then need to be adapted to a mandatory method that is established later.

Finally, it is wise to take into account the fact that a possible CO2 obligation will likely come with requirements regarding substantiation and updating. How often product passport data must be updated once a product group falls under specific requirements is described at how up-to-date the data in the product passport must be.

Where that is stated: Articles 5-7, 10 and 39 of the ESPR

The ESPR (Regulation (EU) 2024/1781) establishes in Articles 5 to 7 that ecodesign requirements — including any climate indicators — are determined per product group via delegated acts, not directly by the regulation itself. Article 10 describes which categories of information can be included in a digital product passport, but this is also concretely specified per product group. Article 39 provides that once a calculation such as a carbon footprint is made mandatory for a product group, this must be done according to an established test, measurement or calculation method — precisely to prevent each manufacturer from using their own method. For furniture, the delegated act that would concretely implement these articles is missing, and with it the obligation.

What to do next

Anyone preparing a passport now can best complete the certain components first — materials, composition, and any substance information — and leave the CO2 question aside until the delegated act for furniture has been published. This page will be updated as soon as that text is available and it is clear whether, how and from when a carbon footprint for furniture becomes mandatory.