how do I obtain passport data from a supplier outside the EU

The importer requests, the supplier delivers

Whoever places furniture from outside the EU on the European market is considered an importer under the ESPR, and that role carries its own obligation: to verify that the digital product passport exists and is correct before the product is placed on the EU market. In practice, this means that the data needed for the passport must be requested from the manufacturer outside the EU — materials, composition, origin of components, and everything else required for that product's passport. The EU importer is not the one who invents or supplements this data with an estimate; that data must come from the manufacturer, and the importer checks what is received.

For whom this applies, and where it transitions to something else

This question is specific to the party designated as the importer: the person who places a piece of furniture from a manufacturer outside the EU on the European market for the first time. For a project furnisher or trader who purchases furniture from an EU importer, it is different — they connect with a supplier already located within the EU, which is a different route than described here. For those who import directly from a country outside the EU, the distinction between "manufacturer" and "importer" under Article 29 of the ESPR is relevant: the importer has its own, independent obligation, separate from what the manufacturer does in the country of origin. What this article does not regulate is how the manufacturer provides the data precisely or in what form — that is something agreed between the parties in practice. More on what the passport concretely means in this import situation is in what the product passport means for imports from outside the EU.

No fixed date yet, but a clear direction

There is no established date yet for when this obligation takes effect for furniture. The ESPR itself is the framework regulation; which product groups must have a passport and when is determined for each product group in a separate delegated act. For furniture, that act does not yet exist. What is established is the mechanism in Article 38 and Article 29: once the obligation takes effect, the responsibility for passing on data in the chain rests with the actors designated by the ESPR for this purpose, and that responsibility does not automatically shift because a manufacturer is located outside the EU. Until the date is set, there is no legal obligation to request this data yet — but nothing prevents an importer from arranging the supply now, precisely because that will save time later. This page will be updated as soon as the delegated act for furniture is published.

How this is addressed in practice

The first step is to establish exactly which data is needed for the passport of the piece of furniture in question — an overview of this is in which data is requested from the supplier. After that, it is advisable not to arrange this supply verbally or by separate email, but to set it out in the purchase agreement with the manufacturer outside the EU: which data, in what form, and at what time. How this is arranged contractually is set out in agreements on the provision of passport data in the purchasing contract. With a supplier outside the EU, this is particularly important because there is no shared EU supervisory framework that holds the manufacturer directly accountable — the importer stands between the manufacturer and the European market, and therefore bears a greater share of the risk if data is missing or incorrect.

Once the data arrives, the next step is to verify it for accuracy and completeness rather than accepting it as is; how this verification is set up is in verifying data for accuracy. If the manufacturer does not provide the data, provides it incompletely, or provides it too late, this is a situation that occurs frequently and for which an approach exists — see what to do if the supplier does not provide the data. It is also important whether this concerns a complete piece of furniture or a semi-finished product that is further processed: for subcontractors and suppliers of components, similar questions apply about who supplies which data, as described at or a subcontractor that supplies semi-finished products must also provide product passport dataAt customs controls on the digital product passport, as provided for in Article 15 of the ESPR, it is the importer who can be held accountable for the absence or incorrectness of this data — a reason to have this chain in order beforehand rather than only during a control.

Substantiation: Articles 29, 38, 10 and 15 of the ESPR

Article 29 of the ESPR describes the obligations of importers, including checking whether the digital product passport is present and correct before a product is placed on the EU market. Article 38 regulates the requirements for actors in the supply chain, and thus the basis for passing on product data between manufacturer, importer and other links. Article 10 describes what the digital product passport must contain in terms of content, which determines which data must first be requested from the manufacturer outside the EU. Article 15 regulates customs controls on the digital product passport at import, which directly affects the importer at the moment a piece of furniture crosses the EU border.

What to do now

If a company is already importing furniture from outside the EU, it can, without waiting for the delegated act, map out which manufacturers are engaged, which data those manufacturers normally already maintain (such as material composition and origin), and whether the existing purchase contracts allow for a supply obligation for passport data to be added later. If you are unsure whether your own products will be subject to the obligation in the future, you will find an initial check at whether the product passport will apply to your furniture.