My manufacturer is outside the EU — who arranges the product passport then?

The importer or authorised representative arranges the passport

When a manufacturer is established outside the EU, responsibility for the product passport lies with the party placing the furniture on the market within the EU. This is usually the importer — the company that imports the furniture from a country outside the EU and sells it in the EU. A manufacturer outside the EU may also choose to appoint an authorised representative in the EU, who then assumes part of the obligations on behalf of the manufacturer. In both cases, the practical task — compiling, verifying and making available the product passport — shifts to a party that is established in the EU.

Who this applies to, and who it does not

This applies to furniture produced outside the EU and subsequently placed on the EU market — via import by a European company, or via a manufacturer that itself sells directly to EU customers without its own establishment in the EU. It does not apply to furniture that is ordered from a factory outside the EU but is imported via a European establishment of that same manufacturer — in that case, that EU establishment itself is the responsible party, not an external importer. It also does not apply to furniture sold exclusively outside the EU and never placed on the EU market; the product passport is an EU obligation linked to placing on the market within the EU, not to the place of production as such.

Important to distinguish: the importer or authorised representative is responsible for arranging the passport, but this does not mean that this party needs to collect all underlying product information itself. The actual data on materials, composition and origin typically comes from the manufacturer itself. The importer or representative ensures that this data exists, is correct and is made available in the appropriate manner — the source of the information and the party bearing the obligation are therefore two different things.

When this enters into force is not yet determined

There is no definitive date yet for when this obligation enters into force for furniture. The ESPR work plan for the period 2025-2030 mentions a delegated act for furniture expected in 2028; only after publication of that act will it be clear from which date furniture actually falls under the passport obligation. Until then, no passport obligations apply to furniture under this regulation. The distribution of responsibilities between manufacturer, importer and authorised representative as laid down in the ESPR itself is already fixed — this structure will not change, only the entry date for furniture specifically must still be confirmed.

How this is handled in practice

Any importer bringing furniture from a manufacturer outside the EU is well advised to first map out which party in the chain holds which data. The manufacturer has the basic information: materials, composition, any certifications. The importer will need to request this information, verify it and convert it into the form required by the product passport once the regulation for furniture enters into force.

A second point is the choice between acting as an importer yourself or having the manufacturer appoint an authorised representative in the EU. With larger volumes or long-term trading relationships, it may be practical for the manufacturer itself to appoint a representative who handles this task structurally, rather than each individual importer having to arrange this themselves. This is a matter of assessment between the parties involved, and not a choice prescribed by the regulation.

Thirdly, it is useful to make agreements now about data provision, even though the obligation for furniture has not yet come into force. Manufacturers outside the EU who provide relevant product information in a structured manner in good time will save the importer or representative a lot of work later. Waiting until the delegated act is published often means that there is little time left to collect data afterwards.

The legal basis: articles 28 and 29 of the ESPR

This division of responsibilities follows from article 29 of the ESPR (Regulation (EU) 2024/1781), which describes the obligations of importers, and from article 28 of the same regulation, which governs the role of authorised representatives. Together, these articles determine that when a manufacturer is not established in the EU, another party within the EU assumes the obligations relating to, amongst other things, the product passport.

What to do now

If you import furniture from a manufacturer outside the EU, it is best to clarify your own role now — as an importer yourself, or in consultation with the manufacturer via an authorised representative — and begin to inventory the product information that the manufacturer can provide. Once the delegated act for furniture has been published and the implementation date is fixed, that information will be added here directly.

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

When a company places furniture from a manufacturer outside the EU on the European market, it assumes a position that is not without obligation. The ESPR distinguishes between who makes the product and who actually places it on the EU market, and with a manufacturer outside the EU, these two roles do not coincide. The obligations then fall to two parties: the importer within the EU, and possibly an authorised representative designated by the manufacturer itself. Whether a company actually falls under this depends on the precise role it plays — this is set out on Am I an importer or a manufacturer according to the ESPR?.

The importer verifies that the product is placed on the market before it is marketed

Article 29 of the ESPR (Regulation (EU) 2024/1781) imposes a controlling task on the importer: to check whether the manufacturer outside the EU has its affairs in order before the furniture is sold in the EU. In practice, this means that an importer of 10 to 100 employees cannot simply resell what is supplied. A check is made as to whether the digital product passport is present, whether the declaration of conformity is correct, and whether the technical documentation exists. For an importer who has so far mainly thought in terms of logistics and commerce — ordering, clearance, reselling — a substantive control task is added here that requires knowledge of the regulations.

The importer ensures that the passport is actually present and remains

This is not just about a single check on arrival. Article 29 expects the importer to ensure that the passport remains associated with the product as long as it is on the market, and that its own data (name, address, contact details) are correctly stated with the product. For a company that purchases from multiple manufacturers outside the EU, this means that a fixed procedure must be in place for each product line to verify that the passport remains current — even after a change in assortment or an adjustment to the product.

The manufacturer may designate an authorised representative

Article 28 of the ESPR gives the manufacturer outside the EU the option to designate an authorised representative within the EU, who will perform the obligations under the regulation on its behalf. This can be the importer, but does not have to be — it can also be a separate party that assumes this role, with a written mandate that specifies which tasks are precisely transferred. For a medium-sized company considering taking on this role, this means a responsibility that goes beyond a mere formality: the authorised representative is responsible for the tasks included in the mandate.

There must always be a contact point within the EU

The core of Articles 28 and 29 together is that there must never be a situation in which furniture is on the EU market while there is no one within the EU who can be held accountable for the product passport. For a company, this means that before purchasing from a manufacturer outside the EU, it is established who fulfils that role: the importer itself, or a designated authorised representative. Without that clarity, a gap emerges that will not automatically be filled by the manufacturer outside the EU — because that manufacturer falls outside the direct scope of EU regulations.

Where things go wrong in practice

An importer assumes that the manufacturer outside the EU 'has sorted it out', because that manufacturer also exports to other countries outside the EU and apparently must comply with regulations there. The ESPR obligation is therefore not verified by itself, with the result that it is only when an inspection takes place in the EU that it becomes apparent that there is no passport.

A company purchases through an intermediary, who in turn purchases from a manufacturer outside the EU. No one in the chain establishes who is formally the importer according to the ESPR — with the result that the obligation is passed back and forth between two parties without either of them actually carrying out the verification.

A manufacturer outside the EU does not appoint an authorised representative, and the importer assumes without written agreement that the manufacturer itself remains responsible for the contents of the passport. In the event of a dispute over incorrect data, there is no recorded agreement about who supplied which information — see also who is liable for incorrect data from a supplier in the passport.

An importer incorrectly assumes that its own brand on the packaging automatically means that the manufacturer outside the EU remains responsible for the passport. However, anyone who sells furniture under their own brand may themselves be regarded as a manufacturer — that distinction is described on I sell furniture under my own brand — what obligations do I get?.

An importer sells via an online marketplace and believes that the platform takes over the obligations. However, the role of the marketplace is separate from the role of the importer — that difference is explained on What does the product passport mean if I sell furniture via an online marketplace?.

What you can put in order now

A written agreement with the manufacturer outside the EU stating who compiles, provides and keeps the digital product passport up to date.
A power of attorney or appointment document, if an authorised representative is appointed in accordance with Article 28 — with a clear description of the tasks being delegated.
An internal checklist used for each new shipment to establish whether the passport, the declaration of conformity and the technical documentation are present, before the furniture is sold on.
A file containing the data provided by the manufacturer outside the EU, including date and version, so that when there is a change it can be established what information was provided and when.
A fixed contact person at the manufacturer outside the EU for questions about the passport, recorded in the purchase agreement.
In case of doubt about who fulfils which role in the chain: an overview of your own position, to be compared with the description on Who is responsible for the product passport for furniture?

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.