which hazardous substances must I mention in the product passport of a piece of furniture

What you concretely have to do

What is expected of you

The ESPR provides in Article 7 that the digital product passport must contain information about the presence of "substances of concern" in a product. For furniture, this means in concrete terms: substances that are classified as hazardous to health or the environment according to the CLP Regulation, and substances on the list of Substances of Very High Concern (SVHC) under REACH, must be reported if they are present in the furniture above a certain concentration threshold. The exact threshold values and the precise scope per product group will be further specified in the delegated act for furniture; that does not yet exist. What is certain, however, is the principle: concealing hazardous substances that are present is not an option once the obligation for furniture comes into force.

Determining which substances are relevant

For a company with 10 to 100 employees, this means in practice that there must be someone who knows which glues, paints, preservatives, flame retardants and coatings are in their own furniture — and which supplier these substances were purchased from. Many companies of this size have that knowledge with the procurement officer or product developer, but it is not documented in a form that you can directly link to a passport. This is the first bottleneck: the information often exists, but is scattered across emails, safety data sheets and the memory of one person.

Enquire with suppliers

Article 7 of the ESPR (Regulation (EU) 2024/1781) places the information obligation on the person placing the product on the market, not automatically on the supplier. This means that a furniture manufacturer who purchases, for example, foam filling, textiles or a metal frame must ask their own supplier whether and which substances of concern are present in them. For textiles and upholstery this is often a point of attention, because chemical treatments (flame retardant, stain resistant) are often applied here that do not always appear as standard on a supplier's datasheet.

Report according to the prescribed method

Article 39 of the ESPR (Regulation (EU) 2024/1781) stipulates that measurements and calculations must be carried out according to an established method, once that method exists. For hazardous substances, this will presumably align with existing CLP and REACH test methods, but the product group-specific implementation for furniture is still missing. Companies that already maintain a chemical file — for CLP labelling or a safety data sheet — have a head start in this regard, because that data is largely reusable.

Distinction with formaldehyde emission

A separate category is formaldehyde, which in furniture is often introduced via particleboard, MDF or adhesives. This is generally addressed separately via an emission class rather than as a separate substance notification; how that class is determined is described at the emission class for formaldehyde. It is advisable not to confuse these two tracks — general substances of concern on the one hand, formaldehyde emission on the other — in internal administration.

Where things go wrong in practice

A first situation that often occurs: a manufacturer purchases fittings, hinges or legs from an external party and assumes that metal components "automatically" do not contain hazardous substances. Surface treatments such as galvanizing or coatings may, however, contain substances that fall under the notification obligation.

A second situation: the adhesive composition of a supplier changes between two orders without this being communicated to the purchaser. The passport of an earlier batch then no longer applies to the new batch, which raises the question of how often data must be kept up to date.

A third situation: a company does not want to share the exact composition of a coating because it is considered a trade secret. This touches on a real tension between transparency requirements and confidentiality, which is explored in more detail on the page about business-sensitive data.

A fourth situation: during refurbishment or repair, a component is replaced with a different material (for example, a new type of foam), without this being fed back to the passport. What this means for the administration is explained at repairs and refurbishment in the passport.

A fifth situation: an importer takes over a complete piece of furniture from a manufacturer outside the EU and has no insight into the chemicals used, because the documentation was provided in another language or incomplete. This is precisely the scenario where reconstructing substance data retroactively is most difficult.

What you can put in order now

• An overview per component of the furniture (frame, filling, upholstery, adhesive, coating, fittings) with the associated supplier and the material or product used — in line with the approach described at materials per component.
• Copies or references of safety data sheets (SDS) for each purchased chemical substance or mixture.
• A standing question in the procurement process to suppliers: does this component contain substances from the REACH SVHC list or a CLP hazard classification, and in what concentration.
• An internal point of contact or role responsible for keeping this list of substances up to date, including a moment when this is reviewed when suppliers or formulations change.
• A template in which for each product line is recorded which substance, in which component, has been used since which production date — so that a change in composition remains traceable to a specific batch or period.
• A note on which data are treated as business confidential and on the basis of which consideration, so that this is not decided ad hoc per request.