What must be included in the disassembly instructions?

Which information it must contain is determined by the Furniture Regulation — not the ESPR itself

The ESPR (Regulation (EU) 2024/1781) does not itself prescriptively specify what must literally be included in a disassembly instruction for furniture. Articles 5 to 7 of the ESPR describe the framework: on the basis of that, performance requirements (Article 6) and information requirements (Article 7) can be established for a product category, including requirements on ease of disassembly, repair, reuse and recycling, and on the instructions a manufacturer must provide for those purposes. The concrete specification for furniture — which components must be named, which steps, which drawings or which text — follows only from the delegated act that is drawn up specifically for furniture. That does not yet exist. Until then, it is known that a disassembly instruction can form part of the possible content of the digital product passport, but not how it must look in detail.

For whom this will apply, and for whom it does not yet

This obligation is intended for manufacturers and importers of furniture that fall under the future product-category-specific regulation for furniture. It does not apply to product categories for which a delegated act has already been established under the ESPR, nor to parts of a piece of furniture that fall outside the scope of that future regulation — which furniture exactly falls within the scheme will only be confirmed once the text is published. It is also important to note that the general provisions in Articles 5 to 7 of the ESPR do not in themselves create a direct obligation: they are the legal basis on which later, product-specific rules can be built. Without those product-specific rules, there is as yet no concrete obligation for a disassembly instruction for furniture.

The date is not yet fixed

There is no entry date yet for a mandatory disassembly instruction for furniture, because the delegated act that must regulate this has not yet been established. What is confirmed: the ESPR itself is in force, and Articles 5 to 7 and Article 10 form the legal framework within which product-specific requirements — such as for furniture — will later be developed. Once the delegated act for furniture is published, it will also contain the date on which the requirements take effect. Until that publication, there is no legal obligation for a disassembly instruction based on the ESPR, and no one can say with certainty which content or which deadline will apply.

What a manufacturer or importer can prepare now

From a practical perspective, it is wise to start now documenting the disassembly sequence of a product: which parts can be detached, in which order, with which tools, and which connections (screw, adhesive, snap-fit) are involved. This is information that many manufacturers already have in part for their own production, repair or warranty purposes, and which can be reused once the formal requirements are known. It is also useful to start inventorying which materials and parts are separately identifiable for recycling, and to store photos, drawings or step-by-step plans in a separate, structured way — separately from marketing material — so that they can later be easily linked to the digital product passport. Those who organize this in advance will not have to start from scratch once the delegated act is published.

Where this is based: Articles 5 to 7 and Article 10 of the ESPR

Articles 5 to 7 of the ESPR (Regulation (EU) 2024/1781) describe the general ecodesign requirements and the possible performance and information requirements that may be established for each product group, including requirements on disassembly, repair and recycling. Article 10 of the same regulation describes the requirements for the digital product passport, in which the product information required under Article 7 must be made accessible. Together, these articles form the legal basis on which a future, product-specific regulation for furniture may make a disassembly instruction mandatory — however, the exact content of that obligation will only follow from that text yet to be published.

If you are now already working with a supplier, designer or adviser on the documentation of a furniture product, it is advisable to record the disassembly data in a structured manner and to follow the publication of the delegated act for furniture through the official channels of the European Commission, so that your own documentation can be supplemented without much additional effort once the requirements are final.

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

The ESPR leaves room for product group-specific requirements to be established through delegated acts. For furniture, it has not yet been determined what exactly must be included in a disassembly instruction — that elaboration will come with the delegated act for this product group. What already follows from Articles 5 to 7 of the ESPR (Regulation (EU) 2024/1781) is the framework along which such an instruction is structured: information needed to repair a product, disassemble it and separate the parts for maintenance, reuse or recycling. For furniture, this concretely means: how do you take the product apart, which parts come loose in the process, and which material is located where.

Recognisability of the disassembly steps

A disassembly instruction is only useful if someone who did not design the furniture can follow the steps. For a company with 10 to 100 employees, this usually means that the drawing or photographs already made during product development are reviewed again with the question: can this be followed without explanation from the designer? For a cabinet with glued panels, that is a different story than for a chair held together with screw connections — the instruction must make clear the distinction between "loosening" and "destroying during disassembly".

Linking to the material information

A disassembly instruction does not stand apart from the question of what material is in each part. Once a part is loosened, it must be clear what happens to it: keep separate for recycling, reuse in another product, or dispose of as waste material. This makes the instruction in practice inseparably linked to the question do I have to record the material for each part of a piece of furniture? — without that link, a disassembly step may be performed, but the follow-up step (sorting, recycling) is not possible.

Inclusion in the digital product passport

Article 10 of the ESPR (Regulation (EU) 2024/1781) regulates which information is made accessible through the digital product passport and to whom. A disassembly instruction is typically information relevant to a recycler or repairer at the end of the product's life, and less so to a consumer simply using the furniture. This raises the question of who actually sees that instruction — a question that is discussed more extensively on the page about who is allowed to view which data from the product passport. For a manufacturer, this practically means: the instruction must be there, but not every detail needs to be visible to everyone.

Currency when design changes

A disassembly instruction created for the first production series can become outdated once a connection, a fastener or a component changes. For a company that keeps a collection in production for several years and makes minor adjustments along the way — a different screw, a different hinge — maintaining the instruction is a recurring task, not a one-time one. How often such data must be updated is described on the page about how up-to-date the data in the product passport must be.

Where things go wrong in practice

A few situations come up repeatedly with companies creating a disassembly instruction for the first time:

The instruction is written by the designer, for the designer. Steps that are obvious to the maker ("the panel clicks out") turn out to be impossible to follow for a repairer or recycler without prior knowledge.
There is an assembly instruction for the end user, but no one has reversed it into a disassembly instruction. The two do not automatically run in parallel — for glued or clicked-in parts, disassembling is a different action than assembling in reverse order.
The instruction describes the steps, but not the materials that come loose in the process. A recycler who takes the furniture apart then knows how, but not what to do with each part.
For upholstered furniture, the upholstery is treated as a single unit, while filling, textile and frame often need to be disassembled and processed separately. This aligns with the points of attention described in recording data on textiles and upholstery.
It is assumed that the disassembly instruction is an established, mandatory document, while the exact content requirements for furniture have not yet been determined. Companies that document something now do so on the basis of the general line from the ESPR, not on the basis of an elaborated standard for this product group.

What you can put in order now

Without the final content requirements being known, it is worthwhile to lay a foundation now that can be supplemented later:

A step-by-step description of disassembly per product model, with photos or drawings, prepared with a reader in mind who has not designed the product.
A link between each disassembly step and the component that comes loose in that step, including the material of that component.
An overview of fastening means (screws, clamps, adhesive bonds) per model, so that it is clear which tool or which method is required.
Version control of the instruction, so that a change in the design is also implemented in the disassembly steps.
A note on who may view the instruction: internal, for repairers, or more broadly — as preparation for the classification that the digital product passport will introduce.

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.