What does the product passport mean if I import furniture from outside the EU?

Upon import, the importer becomes the responsible party for the product passport

Whoever imports furniture from outside the EU and places it on the EU market acts as an importer within the meaning of the ESPR, and responsibility for a correct digital product passport therefore lies with that importer — not (automatically) with the manufacturer outside the EU. This means the importer must verify whether the passport exists, whether it is correct, and whether it is accessible before the furniture enters the EU market. The manufacturer outside the EU typically supplies the data, but the legal responsibility for the passport actually existing and meeting the requirements shifts to whoever imports the product into the EU. In addition, customs authorities have a role: they may check at the border whether a digital product passport is present before a consignment is released for free movement.

Who this applies to, and what falls outside it

This section is relevant for anyone sourcing furniture from outside the EU to place it on the European market: importers in the classical sense, but also companies that have production carried out in a third country and sell the end product under their own name or brand in the EU. It applies to products that fall within the scope of the product passport for furniture once that scope is established — not to every piece of furniture automatically. It does not apply to transit without the product being placed on the EU market (for example, transit to a destination outside the EU), and it does not apply to second-hand furniture that was already in circulation in the EU before the import obligation came into force. Nor is a private individual importing a single piece of furniture for personal use an importer within the meaning of these rules — the obligation is directed at those who place products on the market in the context of a commercial activity.

No fixed date yet, but an established framework

Exactly when this obligation for furniture takes effect is not yet fixed. The ESPR work plan for the period 2025-2030 mentions a delegated act for furniture expected to be adopted in 2028; only after publication of that act will it become clear from which date furniture must actually have a digital product passport, and therefore also from which date importers will be checked on this upon import. Until then, the current rules for furniture imports apply, without the additional requirement of a product passport. What is established, however, is the framework from the ESPR itself: the obligations of importers (Article 29) and the possibility of customs control of the passport (Article 15) are already laid down in the regulation. Only the moment when this becomes concrete for furniture depends on the delegated act that is still to follow. Once it is published, the date will be stated here.

What this means for the importer, step by step

For those who already import furniture from outside the EU and wish to prepare for this, the first step lies with the manufacturer or supplier in the third country: verify whether and how they supply the data needed for a passport, and whether this happens at a time that aligns with the import. The second step is to establish a link between the physical product and the passport — in practice the QR data carrier on or with the piece of furniture, so that it is already present upon arrival in the EU and does not have to be added afterwards. The third step is to retain the underlying documentation: if customs or market surveillance request substantiation, that responsibility lies with the importer, even if the data originally came from the manufacturer. A fourth point is to monitor your own product category: because the date and precise requirements are established per delegated act, the moment when this applies to a particular type of furniture will differ, and it is important to keep track of this once the act for furniture is published.

Where this is provided: Articles 15 and 29 of the ESPR

These two elements — the obligations of importers and the role of customs — follow directly from the ESPR itself. Article 29 of the ESPR (Regulation (EU) 2024/1781) governs the obligations of importers, including the duty to ensure that a product placed on the market is accompanied by the required digital product passport. Article 15 of the same regulation governs customs controls relating to the digital product passport, and thereby provides customs authorities with an instrument to check upon import whether this requirement is met. Both articles apply to products once they fall under a product-specific delegated act; for furniture, that act does not yet exist, as described above.

If you are currently importing furniture from outside the EU, it is advisable to use this moment to make arrangements with your supplier in the third country regarding data provision, so that no backlog arises once the delegated act for furniture has been published and the date is confirmed.

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

Whoever imports furniture from outside the EU and places that furniture on the EU market is classified as an importer under the ESPR. This is a different position from that of a trader who purchases within the EU: the importer is closest to the manufacturer outside the EU and therefore receives its own set of obligations, governed by Article 29 of the ESPR (Regulation (EU) 2024/1781).

Check whether the product passport exists before the product is imported

An importer is expected to verify that a digital product passport has been drawn up for the furniture, and that the passport meets the requirements applicable to that product type, before the product is placed on the market. In practice, this means that the passport is not a matter that can be settled after arrival — it is part of the preparation of the shipment. For a company with 10 to 100 employees, this usually amounts to a fixed step in the purchasing process: enquiring with the factory outside the EU what data it has and whether that data is already available in passport form, or whether a platform such as furnipas.eu must compile that passport on the basis of that data.

Check whether the declaration of conformity and marking are present

In addition to the passport itself, the importer is expected to verify that the manufacturer outside the EU has performed the conformity assessment and affixed the required marking. This is not a technical inspection of the product, but a paper-based check: are the correct documents in place, and do the details on the product match what is stated in the accompanying documents. In the event of repeated import of similar products from the same factory, this often becomes a fixed checklist per shipment rather than a one-off investigation.

State the importer's own name and contact details on the product or packaging

An importer is expected to state its own name, registered trade name or brand name and contact details on the product, the packaging or an accompanying document. This is a practical step that is often organised in the packaging line or during labelling, and which is separate from the passport itself — but is part of the same Article 29.

Ensure that storage and transport do not cause the product to fail to comply with the requirements

As long as a product is under the responsibility of the importer, it is expected that storage and transport conditions do not jeopardise compliance with the requirements. For furniture, this means in particular that the data underlying the passport — material composition, origin, treatment — remain accurate during transport and storage, and are not based on a production status that has since changed.

Cooperate with customs authorities in checks on the digital product passport

Article 15 of the ESPR (Regulation (EU) 2024/1781) provides that customs authorities may carry out checks on the digital product passport when products from third countries are placed on the market. For the importer, this means that the QR data carrier and the underlying data must already be available and accessible at the time of import — not only after the shipment has been cleared. A company that regularly imports is therefore expected to treat the passport as part of customs documentation, not as something that "comes along".

Where things go wrong in practice

A common situation is that the factory outside the EU can provide material data, but has no idea what a digital product passport involves or what format is expected. The importer often only discovers this when the shipment is already on its way, and then faces data that is incomplete or not in the correct format. What exactly needs to be requested from a supplier outside the EU is clarified too late in the process.

A second situation: the importer assumes that the factory has already had the DPP drawn up itself, while that factory in turn assumes that the EU-responsible entity will arrange this. Without an explicit agreement, this question remains unresolved between the two parties until someone — usually at customs — asks about it.

A third situation arises when the same furniture model is sourced from two different factories outside the EU, for example to spread supply risk. One factory supplies detailed data on wood origin and glue composition, the other supplies a basic specification. Without standardization, two different DPPs are created for what the customer sees as the "same product". How to prevent this when sourcing the same component from different suppliers is therefore also relevant for importers, not only for companies that source within the EU.

A fourth situation: the data supplied proves upon sampling not to match the physical product — for example a different type of board material than specified. This only becomes apparent when there is actual verification that the supplier's data is correct, something that does not automatically happen with imports from outside the EU because the distance to the factory is greater and there is less direct visibility of the production process.

A fifth situation: wood origin is mentioned in the supplied documentation, but without supporting documents. With furniture this is a recurring point, and recording the origin of the wood it therefore becomes one of the more difficult parts for importers to obtain from a factory outside the EU in the first place.

What you can put in order now

A written agreement with the factory outside the EU on which DPP data will be supplied, in what format and at what point before shipment — to be recorded in a way that is comparable to agreements on the supply of DPP data in a purchase contract.
An overview of exactly which data are required per product category, so that this does not have to be worked out again per shipment — see also which data are requested from a furniture supplier.
A file per shipment with the declaration of conformity, the marking and the underlying material data, so that this is immediately available during a customs inspection.
A fixed procedure for when it is established that a supplier does not supply the data, does not supply it completely or supplies it too late — including what is to be done afterwards, as described in a supplier that does not supply the data.
An internal check as to whether it is a finished furniture piece or a semi-finished product that is further processed in the EU, because this affects the question of whether a subcontractor supplying semi-finished products must also supply DPP data.
A decision on whether the supplied data are checked internally or whether an independent verification by a third party is engaged for this purpose, and at what point in the process that occurs.

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.