how do I create passports for a furniture collection with many colour and fabric variants

Each variant with its own characteristics receives its own passport

A collection with many colour and fabric variants fundamentally demands one design choice: determining at what level a variant is genuinely different from the rest. A sofa sold in ten upholstery options is not automatically ten different products for the product passport — but the upholstery often does determine data that belongs in the passport, such as material composition, origin of the textile, or fire safety treatment. Once those data differ per variant, the content of the passport also differs, and so does the unique identification code that attaches to the passport according to article 12 of the ESPR (Regulation (EU) 2024/1781). The practical approach is therefore: one basic structure for the model, and per variant only adjust the fields that are actually different.

For whom this matters, and what does not

This is relevant for manufacturers and importers who bring one furniture model to market in multiple versions: different fabric, different leather, different paint colour, different frame wood. It does not apply to purely aesthetic choices without consequences for material or composition — a fabric that differs only in colour shade but is identical in fibre composition, flame retardant, and origin does not substantively change the passport content. It is therefore not about the number of SKUs on the delivery note, but about the number of substantively different product variants. A collection with fifty colour codes may, in terms of passport content, amount to just two or three variants, if the colour otherwise changes nothing about what is in the product. This distinction is not separate from the question of whether the passport for a particular piece of furniture is compulsory at all — that basic question is answered on the page on whether the product passport applies to your furniture.

The obligation follows the delegated act per product category

When the passport for furniture becomes compulsory is not yet fixed. The ESPR itself (Regulation (EU) 2024/1781) is the framework; the actual obligation for furniture arises through a delegated act established per product category, and that act does not yet exist for furniture. Until that act is published, there is no statutory deadline to work towards — it is clear from the ESPR work plan that furniture is on the agenda. As soon as the date is set, it will be stated here. Until then, designing a variant structure is not an obligation but a preparation, and that preparation is precisely where time can be gained — see also what can already be done while the rules are not yet final.

How a collection with variants is built in practice

The sequence that reduces the most noise starts with the model, not the variant. First, data are established that apply to the whole model: construction, dimensions, function, standard components that are identical in every version. Then per variant only what differs is recorded — usually the upholstery, sometimes the finish of the frame. That separates "fixed" data from "variable" data, and that separation is exactly what a product database must be able to support; anyone who already has a database with article numbers and material specifications per variant can check whether that structure can be reused via the advice on making an existing product database fit for purpose.

A second step is determining the identification code per variant. Article 12 of the ESPR requires a unique identification code for the product to which the passport relates; in the case of variant-rich collections, this in practice means that each substantively different variant receives its own code and thus its own passport database entry, while variants without substantive difference can fall under the same code. This prevents two problems: on the one hand, creating hundreds of passports for variants that are factually identical, on the other hand, using one passport for variants that do materially differ.

A third step is the QR data carrier. Article 9 of the ESPR links the passport to a data carrier on the product, and with a collection containing variants it is practical to think about where and how that carrier is applied per variant — an upholstery with a different material passport requires a different QR code than upholstery that is materially identical. Anyone who wishes to work through this step by step, including the question of when in the production process the code is assigned, will find a complete overview on the page on how to approach the product passport step by step.

The basis: Articles 9, 10, 11 and 12 of the ESPR

The foundation of this approach lies in four articles of the ESPR (Regulation (EU) 2024/1781). Article 9 makes the digital product passport itself mandatory for product groups that fall under a delegated act. Article 10 describes the requirements that the passport must meet, including the link between product information and the data actually contained in the passport. Article 11 governs the technical design and operation of the passport, which forms the basis for the question of how data is structured per variant. Article 12, finally, requires a unique identification code per product — the determining factor in the question of whether a colour or fabric variant needs its own passport or not.

Any company already working with a collection is best advised to start by separating fixed model data and variable variant data in its own administration, so that this structure is ready as soon as the delegated act for furniture fixes a date and concrete data requirements.

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

A sofa that is available in twelve fabric types and eight colours is in practice not one product but dozens of combinations. For the digital product passport, this question is not cosmetic: it determines whether there will eventually be one passport with variants in it, or a whole series of separate passports. If a company does not sort this out in advance, it will find itself stuck at the end of the process with a product database that does not align with what the ESPR requires.

What is expected of you

Making each product identifiable

Article 12 of the ESPR (Regulation (EU) 2024/1781) requires a unique identification code per product. With a collection containing variants, this means a choice: does each colour-fabric combination receive its own code, or is one basic code used plus a variant identifier? For a company with 10 to 100 employees, this is primarily an IT question: the product database or ERP system must already distinguish variants in this way, otherwise the problem only arises when creating the passports themselves. Anyone who now checks or whether the existing product database can be made suitable, prevents this question from only being discovered at the first delivery.

Display the correct information per variant

Article 9 of the ESPR describes what the digital product passport must contain. For furniture with fabric variants, part of that information differs per variant — flame retardant treatment, abrasion resistance, fibre composition — and part does not: construction, dimensions, origin of the frame. In practice, this means that the data must be recorded at variant level at the source (manufacturer or fabric supplier). A supplier who only provides "polyester mix, various colours" does not provide enough to complete a passport per variant.

Technology that can process variants

Article 11 of the ESPR sets requirements for the technical design and operation of the passport, including how the passport is linked to the product and how the data remains accessible. For a collection with many variants, this aligns with the question of how the QR code is applied to the product itself: one label per article number does not work if the article number is separate from the colour-fabric combination that the customer actually receives. This is one of the points where a good approach in advance can make a difference: see the more detailed explanation in the step-by-step approach to the product passport.

Meet requirements, including in combinations

Article 10 of the ESPR sets out the requirements that the digital product passport must meet, including the reliability and timeliness of the data. With variants, this applies in a specific way: when a fabric type is replaced or a colour is withdrawn from the collection, this must be processed in the passports of the affected variants, without affecting the passports of the remaining variants. This requires a data structure in which variants can be updated independently of each other.

Where things go wrong in practice

One passport for the entire collection. A manufacturer creates one passport for "sofa model X" and refers in it to "various upholsteries". This does not work once a customer or supervisor wants to know which fire test applies to the specific fabric on their sofa.

Variant data missing from the fabric supplier. The furniture manufacturer itself keeps careful track of which frame, which legs and which finish belong to a model, but the fabric comes from an external supplier who only provides a collection name, not the underlying test results per colour. When filling in the passport, it turns out that some of the data per variant is simply not available.

Article codes that do not match what is sold. Internally, one article number is used per model, and the colour/fabric choice is only fixed at order line level. If the unique identifier from Article 12 is assigned at model level rather than at variant level, a mismatch arises between the passport and the physical product at the customer's site.

Minor changes to the collection that are not implemented. A fabric type is replaced after a season by a similar, but not identical fabric. The passport of the old variant remains online as if it is still available, or — conversely — the new variant is accidentally assigned the passport of the old fabric.

Starting too late with the variant structure. A company waits to set up the data structure until the obligation becomes concrete, and then discovers that hundreds of existing variants must be classified retroactively. Anyone who now examines what needs to be done while the rules are not yet final, can avoid this catch-up by putting the structure in order now, even before a mandatory date is set.

What you can put in order now

A variant list per model, with a separate code or clearly linked variant characteristic for each colour and fabric combination, so that the identifier from Article 12 can be properly applied.
An overview of which data differs per variant and which data is the same for the entire model range — this separates what only needs to be filled in once from what must be provided separately per variant.
Agreements with fabric and material suppliers on the supply of test results and composition per colour or pattern, not just per collection.
A procedure for collection changes, so that a replaced fabric or discontinued colour is also updated in the passport or archived at the moment the change is implemented in sales.
A link between article number, order line and passport, so that the variant actually supplied corresponds to the variant whose passport is displayed.

Whether a specific collection falls under the obligation and from when is described on the page on whether the product passport applies to your furniture. However, the structure of the variant data can be set up independently of this — that work is never wasted, whatever date ultimately applies to the obligation.

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.