Must I record the material for each component of a piece of furniture?

Not yet established, but mentioned as a possibility

No, there is currently no established requirement anywhere that the material of each component of a piece of furniture must be registered separately. The ESPR (Regulation (EU) 2024/1781) is a framework regulation: Article 10 determines what types of information a digital product passport may contain, including data on materials, components and composition, but how detailed this becomes — at product level, at material level or down to each individual component — is not worked out in the regulation itself. That specification will only come with the delegated act that is being drawn up specifically for furniture. Until that exists, there is no established obligation to record material per component, only the possibility that this may be required in the future.

For the framework yes, for the precise content not yet

The ESPR applies in general terms to products that fall under the EU's ecological design policy, and furniture is named as one of the product groups for which work on a delegated act is provided for. Article 7 mentions material composition as one of the subjects on which information requirements can be set. This is different from a concrete obligation to register the material separately for each component — for example the frame, the covering, the legs and the fastening materials. That level of detail is determined per product group, not generically for all products falling under the ESPR. For furniture, that working out does not yet exist. What is thus established: material information belongs in the passport. What is not yet established: at what level of detail.

The date is not yet fixed

There is no published delegated act for furniture yet, and therefore no established entry date for any obligations regarding material registration per component. According to the ESPR Work Plan 2025-2030, the delegated act for furniture is expected in 2028, but this is a schedule, not a commitment on a date. Until the act is published, there are no product-specific requirements under the ESPR for furniture on the level of material registration. The general provisions of the regulation, such as Article 10 and Articles 5 to 7, are in force as a framework, but without the implementation per product group they do not yet have direct, enforceable content for furniture manufacturers on this specific point. As soon as the delegated act appears, this page will be updated with the precise date and the precise requirement.

What to do while the requirement does not yet exist

Anyone wishing to prepare for this should start in practical terms with their own material records: finding out what materials are in which components of a product, even if this is not yet required. This is often already available from procurement or production, only not always structured per component. The second step is to follow the publication of the delegated act for furniture, because only from that will it become clear whether, and at what level, material registration per component becomes mandatory — this could be per main material, per constituent component, or something in between. The third step is to avoid recording detailed systems too early that will not match the final requirement; a reasonable middle way is to maintain material data at a level that can later be easily refined or merged. Anyone having a product passport drawn up now would do well to ask what level of detail is being used for this and whether it aligns with what is seen as probable in the sector, without this being taken as a guarantee for the future requirement.

Where this is based on: Article 10 and Articles 5 to 7 ESPR

Article 10 of the ESPR describes the categories of information that a digital product passport may contain and stipulates that the exact content per product group is established. Articles 5 to 7 form the broader framework of ecodesign: article 5 describes that ecodesign requirements can be set, article 6 concerns performance requirements and article 7 concerns information requirements, including information on material composition. None of these articles contains a concrete requirement that material per component of a piece of furniture must be recorded; they provide the legal basis on which this can be specified via a delegated act per product group. For the exact, applicable text, reference is made to the sources below.

If you are already working on a product passport for furniture, it is best to start by organizing the existing material data per component insofar as it is already known, without anticipating an obligation that has not yet been established, and keep an eye on the publication of the delegated act for furniture for the final requirement.

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

The ESPR itself does not yet stipulate in articles 5 to 7 whether material data per component of a piece of furniture must be recorded, or whether a summary overview of the materials used at product level is sufficient. This clarification is part of the product-specific implementing method (delegated act) for furniture, which does not yet exist. What is established: article 10 of the ESPR determines that the digital product passport must contain the information prescribed in the applicable delegated act, and material composition is one of the categories that belongs in it. The level of detail — per component, per material group, or at product level — remains open.

Record material composition at the level that regulation will require

For a company with 10 to 100 employees, this means above all: start administering now in such a way that breakdown afterwards is possible, without waiting until the exact requirement is known. A production process in which a manufacturer knows which wood, which plastic, which textile and which metal components have been used in a cabinet, sofa or chair can, with a bit of discipline, be traced back to a list per component — provided that information is recorded at the time of purchase or assembly. Companies that do not make this connection will find when submitting the passport that constituent information must be reconstructed from invoices, order confirmations and calls with suppliers.

Align with what must already be in the passport

Material data are linked to other mandatory parts of the passport. Which substances precisely belong in the passport are described on the page about what data will be included in the product passport for furnitureMaterial composition is one information category among several, and the level of detail in which it is requested also determines how much work it costs to provide it.

Take into account the relationship between material and other mandatory data

The level of detail in material registration has an effect on other obligations. The percentage of recyclable material, for example, can only be calculated correctly for a product with multiple material types if it is known which components the product consists of and what material those components are made of. How that calculation works is explained on the page about the recyclability percentage of a piece of furniture. The presence of hazardous substances is also relevant per material component: a foam filling, an adhesive layer or a surface treatment can contain a different substance than the frame. What must be reported in this connection is described on the page about hazardous substances in furniture.

Where things go wrong in practice

A few situations come up repeatedly in companies preparing for the passport.

Composite components are registered as a single material. A seat cushion often consists of a wooden or metal frame, foam filling, an inner cover and an outer upholstery. In the administration of many manufacturers this is listed as "cushion" with one material description, whereas it is actually four material streams. This is even more pronounced with textiles and upholstery, because fibre composition and treatment can differ per layer — see the explanation about recording textiles and upholstery in the product passport.

Suppliers provide only a trade name, no material composition. A sheet material, adhesive type or coating is often purchased under a brand name without the underlying composition being routinely shared. As long as there was no passport requirement, this was not a problem. Once material data per component are needed, this information turns out not to be readily available, especially not retroactively for products that have been in the range for months or years.

Metal fittings and fastening materials are overlooked. Screws, hinges, metal legs — these components are often seen as "accessories" and not as material that is recorded separately. With a detailed requirement per component, these do fall under the registration.

Material registration is not linked to the product version. A manufacturer changes a foam type or replaces a supplier of sheet material, but the existing documentation is not updated. When the passport of an older model is requested, the material information no longer matches what is actually in that product. How often passport data must be current is described on the page about how up-to-date the data in the product passport must be.

Repair or refurbishment parts differ from the original without this being recorded. When a component of a piece of furniture is replaced — for example an upholstery or a frame component during refurbishment — the replacement material may differ from the original composition. Whether and how this should be included in the passport is addressed on the page about repairs and refurbishment in the product passport.

What you can put in order now

A material list per product component (frame, filling, upholstery, fittings, coating), with per component the material type and where possible the origin.
Procurement documentation from suppliers in which material composition is specified, not only a trade name or article code.
A version history per product model, so that changes in material use are traceable to production date or batch.
Technical datasheets of sheet material, foam, adhesive and coatings, archived per supplier and material variant used.
A link between material registration and the calculation of the recyclability percentage, so that both are consistent.
Overview of metal and plastic small parts (screws, hinges, feet) that otherwise fall outside the regular material registration.
Notes about material changes during repair or refurbishment, including the time when the change was made.

These components become easier to manage with a template that brings structure to material registration per component, so that the data are ready once the delegated act for furniture establishes the exact requirements.

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.