How do I determine the formaldehyde emission class of a piece of furniture?
Emission class follows from product rules yet to be established
There is currently no prescribed method for determining the formaldehyde emission class of furniture under the ESPR (Regulation (EU) 2024/1781). The regulation is a framework law: it governs how the European Commission can establish ecodesign requirements per product group, including requirements on chemical composition and emissions (Articles 5 to 7). For furniture, this product-specific elaboration does not yet exist. As long as it does not exist, there is also no test method, class classification or limit value for formaldehyde emissions from furniture prescribed by the ESPR. Article 39 of the regulation does determine that once substantive requirements are introduced, test, measurement and calculation methods will also be established to enable compliance with them — this mechanism is in place, but has not yet been implemented for furniture.
What this does and does not concern
This section addresses the question of whether, and how, a formaldehyde emission class will become part of the digital product passport for furniture under the ESPR. It does not concern any other existing regulations on formaldehyde in products — these may have their own legal basis, their own test standards and their own limit values, separate from the ESPR. Because such other regulations are not contained in the sources used here, they are not covered in this section; those seeking clarity on this should refer to regulations that specifically address that substance and that field of application. What is established here: the ESPR gives the Commission the authority to establish additional, product-specific requirements for a product group such as furniture (Article 5), including performance and information requirements (Articles 6 and 7). A formaldehyde emission class could, if the Commission chooses, form part of such a performance requirement — but that is currently a possibility, not an established fact.
No fixed date, but a timeline
There is no fixed date on which requirements for formaldehyde emissions from furniture under the ESPR will take effect. The delegated act that should regulate this for furniture is on the Commission's work plan for the period 2025-2030 and is expected in 2028. This is a timeline, not a commitment: the date may shift, and the content of the act — including whether and how a formaldehyde emission class features in it — is not yet fixed. Until the delegated act is adopted and published, there are no obligations under the ESPR on this point. Once the text is available, the date and content will be added to this page.
How to proceed until the rules are in place
For those currently manufacturing, importing or specifying furniture, the first step is simply to establish that there is currently no ESPR obligation to determine or report a formaldehyde emission class — such an obligation can only arise after publication of the delegated act for furniture. The second step is to put in order internally what will be needed in future: record data on materials used (in particular substrate materials such as particleboard or MDF, where formaldehyde emissions typically play a role) in a manner that is traceable and current. This is work that will be necessary for a product passport anyway, regardless of which specific substance or emission requirements ultimately apply. The third step is to monitor publication of the delegated act, as it is only then that it will become clear whether an emission class will be introduced, which test method will accompany it (via Article 39) and which standard will be designated for it. Only after that method is known does it make sense to have furniture actually tested and the result recorded — testing on the basis of a method that has not yet been established does not produce data that will be usable in the future passport.
The legal basis: Articles 5, 7 and 39 of the ESPR
That there is no method yet follows directly from the design of the regulation. Article 5 provides that the Commission shall, for each product group, via delegated acts, establish ecodesign requirements; without such an act for furniture, there are no specific requirements. Article 7 governs that such requirements may consist of performance requirements (such as a limit value or class for emissions) and information requirements (such as inclusion in the product passport) — but this too is a power that only becomes effective once the Commission fills it in for furniture. Article 39 builds on this by determining that conformity with such requirements shall be assessed on the basis of test, measurement and calculation methods that the Commission establishes or designates, usually with reference to harmonised standards. As long as no performance requirement on formaldehyde emissions has been established for furniture, no method has been designated to measure it either.
Anyone wishing to continue following this subject would do well to monitor the publication of the delegated act for furniture and in the meantime get the material data of the sheet materials used in order — this is the basis on which, once the method is known, an emissions class can be determined and included in the product passport.
This is based on
- Regulation (EU) 2024/1781 (ESPR), Articles 5 to 7 (ecodesign requirements, performance and information requirements)
- Regulation (EU) 2024/1781 (ESPR), Article 39 (test, measurement and calculation methods)
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
Determine that formaldehyde emission is relevant data for the product passport
For furniture in which sheet material is incorporated — particleboard, MDF, plywood, OSB — formaldehyde emission plays a role because this type of adhesive releases formaldehyde. The ESPR leaves room in Articles 5 to 7 of Regulation (EU) 2024/1781 to determine per product group which performance requirements and information requirements apply; for furniture it has not yet been established whether and how an emission class becomes a mandatory part of the product passport. For a company with 10 to 100 employees, this means in particular: establishing which sheet materials are in the range and whether an emission class is already known for these, so that this information is ready as soon as the requirement becomes concrete. This also touches on the question which data are included in the product passport for furniturebecause formaldehyde emission is one of the possible data points alongside other material and substance-related information.
Be able to substantiate an emission class with a recognised test method
Formaldehyde emission classes (think of the familiar E1-type classifications that are common in the sheet materials industry) are determined using specific test methods, such as chamber test or gas analysis methods for sheet material. Article 39 of the ESPR stipulates that test, measurement and calculation methods must be reliable, accurate and reproducible, and that harmonised standards are preferably used. Which standard exactly will apply for furniture within the product passport is not yet established. For a manufacturing company, this means that the emission class of purchased sheet material must be obtainable from the supplier, and that own testing of the final furniture product is not currently laid down as a fixed obligation. The general question according to which method must I measure the values for the product passport applies here as well, because the methodology ultimately determines which figure or class ends up in the passport.
Tracing back the emission class to the correct part of the furniture
Furniture often consists of multiple materials: a frame of particleboard, a back panel of MDF, legs of solid wood. If an emission class becomes relevant for the passport, it is logical that this does not apply to the furniture as a whole, but to the specific part in which the relevant sheet material is incorporated. This aligns with the broader question must I record the material for each component of a piece of furniture: as soon as material registration per component is established, the emission class can logically be linked to it. For a company with a broad range, this means that the administration of sheet material per product component must be in order if the emission class is to be easily added to the passport later.
Monitor the currency of data when suppliers or recipes change
Sheet material from different suppliers, or a changed adhesive composition, can result in a different emission class. As soon as this data becomes part of the passport, it is reasonable to assume that changes in the raw material or production process will also require an update of this data. This touches on the question how often must I update the data in the product passport. For a company that regularly changes sheet material suppliers, this means that a fixed procedure to identify and process this change is useful, even if the exact update obligation is not yet established.
Where things go wrong in practice
- A project manager takes over the emission class of the sheet material from the supplier without checking according to which standard that class was determined, and later finds out that the test method does not align with what is needed for the passport.
- A manufacturer registers one emission class for the entire piece of furniture, while different parts (frame, back panel, drawers) consist of sheet material from different suppliers and thus possibly different classes.
- When changing sheet material suppliers, the new emission class is not implemented in the company's own product documentation, so the passport would display outdated or incorrect data.
- A company assumes that a quality mark on the packaging of sheet material automatically yields a valid emission class for the product passport, without verifying whether that quality mark aligns with the method that ESPR legislation will later prescribe.
- Formaldehyde emission is treated as a separate, isolated item, whereas in practice it is often requested together with other substance-related information — which affects the overview of which hazardous substances must I mention in the product passport of a piece of furniture a more logical starting point than treating formaldehyde as a standalone piece of data.
What you can put in order now
- An overview per sheet material supplier, with the stated formaldehyde emission class and the test method or standard on which that class is based.
- A link between this supplier overview and the material registration per component of the furniture, so that it is clear which component has which emission class.
- A fixed moment in the purchasing process at which the emission class of new sheet material is checked and recorded, for example when concluding or renewing a supplier contract.
- Certificates, test reports or declarations of conformity from the supplier that support the stated emission class, archived per product component.
- A notification arrangement with suppliers that changes in formulation or raw material that may affect the emission class are communicated.
- A reference in the company's own product administration to the source of the emission data, so that in the event of a future passport requirement, it can quickly be demonstrated where the figure comes from.
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.