How do I document the origin of the wood?
The exact data on wood origin are not yet fixed
There is no legally prescribed method yet for recording the origin of wood for the digital product passport, because the specific data requirements for furniture still need to be established in a delegated act. The ESPR (Regulation (EU) 2024/1781) does set the framework: the passport contains information determined per product group, and all actors in the supply chain must provide accurate and complete data about the product. For furniture, that framework exists, but the concrete list of fields — for example wood species, country of origin, felling permit or certification scheme — is not yet fixed. Anyone who starts now with origin registration is building a file that can probably (partly) be reused later, but does so on the basis of their own assessment, not on the basis of an obligation that is already in black and white somewhere.
For whom this is relevant, and for whom it is not yet
This question is relevant for furniture manufacturers, importers and project outfitters who are already thinking about the structure of their product information, in anticipation of the digital product passport for furniture. This specifically concerns origin data for wood as a raw material — not for other materials such as metal, textiles or plastic, which have their own points of attention. It is also not about wood products outside furniture, such as building materials, which may fall under other legislation (such as the EU Deforestation Regulation, which is not addressed here). And it is not about an obligation that already applies today: no delegated act for furniture has been published yet, so there is also no binding requirement on which origin data must be included in the passport or how detailed they must be.
What is already fixed and what still needs to be filled in
When origin data on wood must be included in the passport is still unknown. The ESPR work plan 2025-2030 mentions a delegated act for furniture expected in 2028, but that is a schedule, not a fixed date. Once that act is published, the exact entry date will appear here. Until then, it is established that the ESPR itself is already in force and sets the general framework: the passport is built from information that the manufacturer or importer provides, and that information must be correct. What is not yet fixed is which origin data on wood are specifically required, in what form, and with what evidence. That will only become clear with the delegated act for furniture.
How a manufacturer or importer handles this practically now
Anyone who wants to record origin now starts with their own purchasing: per wood species and per supplier, noting where the wood comes from, preferably down to the level of the country or region of felling. A second step is collecting what evidence already exists — supplier declarations, invoices with origin indication, and certificates from schemes such as FSC or PEFC, insofar as these are used. This is not a legal obligation under the ESPR itself, but it aligns with Article 38, which requires that actors in the supply chain provide accurate and complete information needed for the passport to whoever compiles the passport. A third step is keeping this organized per product line or per collection, so that it does not have to be looked up again per individual component. A fourth step is keeping this file current: suppliers change, wood species change, and a passport that lasts ten years requires data that remain correct over time. Anyone who puts this in order now will not have to start from scratch when the delegated act for furniture is published, but can supplement the existing origin data with what is specifically requested then.
The basis in Article 10 and Article 38 of the ESPR
Article 10 of the ESPR (Regulation (EU) 2024/1781) sets out what the digital product passport must contain and determines that the precise information requirements per product group will be established — for furniture, this is still to come. Article 38 of the same regulation obliges actors in the supply chain to provide the information needed to meet the passport requirements, accurately and completely, to the person compiling the passport. Together, these articles provide the framework: an obligation to share product information will emerge, including possibly traceability data on materials, but the exact specification for wood in furniture will follow with the delegated act.
What to do
Start by inventorying the wood species and suppliers that appear in your own collection, and collect the available certificates of origin or certifications available per supplier. Document this in an overview linked to product lines, so that it can easily be linked to a digital product passport later. Monitor the publication of the delegated act for furniture — as soon as it appears, the concrete date and the precise data requirements will be added to this page.
This is based on
- Regulation (EU) 2024/1781 (ESPR), Article 38 (requirements for actors in the supply chain)
- Regulation (EU) 2024/1781 (ESPR), article 10 (requirements for the digital product passport)
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
Collect and transfer source data in the supply chain
Article 38 of the ESPR (Regulation (EU) 2024/1781) describes that actors in the supply chain provide the data necessary to compile a product passport. For furniture with wooden components, this means that data on the origin of the wood — where it comes from, through which stages it is processed — is recorded somewhere in the chain and passed on to the party compiling the passport. For a furniture company with 10 to 100 employees, this usually comes down to requesting this data from their own wood supplier or sheet material producer, and forwarding it to the party drawing up the passport. In practical terms, the first question is therefore not "how do I register this myself", but "where do I get this information from, and in what form". An overview of which data you must request from your furniture supplier provides a starting point for what can be concretely requested.
Include origin information in the product passport
Article 10 of the ESPR describes what type of information goes into a digital product passport: data relevant to the sustainability and origin of the product and its components. For a wooden piece of furniture, the origin of the wood falls under that category of information, alongside other characteristics such as material composition. What this concretely means for a company depends on the delegated act that is specifically drawn up for furniture — it ultimately determines what level of detail is required (for example: country of origin, forest management certificate, or intermediate processors). As long as that act has not been published, it is advisable to collect origin data in as much detail as possible, so that a company does not have to reconstruct afterwards what was purchased five years earlier.
Keep data current and traceable
Origin information is not a snapshot. A supplier can change forest manager, wood species, or country of purchase, without the product name or article number changing. For a product passport that is hosted for ten years, it is important that origin data remain linked to the correct production batch or period, not only to the article number. In practical terms, this means that a company not only asks "what is the origin of this wood", but also records when that information was provided and for which delivery it applies.
Where things go wrong in practice
A first situation that often occurs: a furniture maker purchases sheet material from a wholesaler, who themselves purchases from various sawmills. The wholesaler only provides "Europe" or "certified wood" as an answer, without underlying documentation. That is too vague for a passport that requires traceable origin.
A second situation: the same component — for example, a solid oak base frame — is purchased from two suppliers, depending on availability and price. Without a system that records per delivery which supplier and which origin the wood comes from, a passport is created that is factually incorrect as soon as both wood flows have been used together. An approach to this is described on the page on what to do if the same component is purchased from different suppliers.
A third situation arises with subcontractors who supply semi-finished products, such as pre-cut frames or steamed components. That subcontractor is often not seen as a "supplier" in the administration, while the wood he processes does end up in the final product. Questions about whether such parties also need to provide data are addressed on the page on subcontractors supplying semi-finished products.
A fourth situation: a company imports furniture or components from outside the EU and adopts the statement of the foreign factory without further review. When importing from outside the EU, there are points of attention that do not apply when purchasing within the EU, including because control and traceability of origin claims are more difficult to organize from a distance. This is further elaborated on the page on what the product passport means when importing furniture from outside the EU.
A fifth situation is that a company receives the origin data but never checks whether they are internally consistent — for example a certificate number that does not match the stated wood species. This remains unnoticed until a passport has already been published.
What you can put in order now
- Origin declaration per delivery: a document in which the supplier indicates for each shipment or batch where the wood comes from, not merely as a general company statement but linked to a specific delivery.
- Certificates of forest management or chain certification: copies or references to valid certificates (for example FSC- or PEFC-type systems), including validity date, so that expired certificates do not go unnoticed.
- Purchase contract with a provision on data supply: an agreement that the supplier provides origin data with each delivery, and not only on request. How such a provision is to be included is described on the page on recording the supply of passport data in the purchase contract.
- Internal linking between batch and origin: a simple overview (spreadsheet or part of the ERP system) in which for each production batch the wood origin used is recorded, so that this does not have to be reconstructed later.
- Check point upon receipt of data: a fixed procedure to verify whether the received origin information is complete and internally consistent, before it is passed on to the passport. An approach to this is described on the page on checking a supplier's data for accuracy.
- Action item for missing data: a fixed procedure for what happens if a supplier does not provide or provides insufficient origin information, including a timeline for follow-up. See for this the page on what to do if a supplier does not provide the data.
These records are not an end in themselves, but build up the file with which a product passport can subsequently be compiled and substantiated — even if the delegated act for furniture at a later time sets specific requirements for origin information.
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.