My product needs multiple digital product passports — how does that work together?
Each regulated component receives its own passport, linked via a code
When a product consists of multiple components that are each separately subject to a passport obligation, the entire product does not receive a single overarching passport. Instead, each regulated component in principle receives its own passport, drawn up according to the rules applicable to that component. For a piece of furniture, this means that the passport of the cabinet, sofa or chair itself is compiled according to the rules that will apply to furniture as a product category under Article 9 of the ESPR (Regulation (EU) 2024/1781), while a built-in component that already falls under its own EU legislation with its own passport obligation — a battery is the clearest example — retains its own passport according to that other regulation. These two passports are not separate from each other: the ESPR provides for unique identification codes (Article 12) which can be used to determine which component belongs to which product. This is therefore not a matter of entering the same data twice, but rather of multiple separate passports that can be linked to each other via that code.
For furniture with a built-in regulated component
This issue arises particularly with furniture that contains a component that is itself already subject to its own passport or registration obligation, such as an electrically adjustable bed, a desk with a built-in battery, or a sofa with integrated electronics. The furniture as a whole will be subject to the furniture regulation in the future; the built-in component will be subject to the regulation that already applies or will apply to it. This does not concern the situation where a manufacturer sells the same furniture model in multiple versions — that is a question about one passport for a product model, not a question about multiple passports side by side. It also does not apply to packaging or transport: these fall outside the product passport as set up in the ESPR. And it does not apply to furniture without any regulated component: once the furniture regulation is in place, there is simply one passport for the furniture itself.
The date is not yet fixed
No date has yet been set for when a product passport becomes mandatory for furniture, and therefore there is also no concrete regulation for how the interaction between the furniture passport and the passport of a built-in component will work in practice. According to the ESPR Work Plan 2025-2030, the delegated act for furniture is expected around 2028; once that act is published, it will be clear when the obligation comes into force and how the requirements for the furniture passport are to be implemented in detail. Until then, there is no passport obligation for furniture. What is already established, however, is the framework from the ESPR itself: that different passports can be linked to each other via unique identification codes, regardless of which delegated act for which component ultimately applies.
What this means for those already making furniture with electronics or batteries
If you already design or supply furniture with a built-in electrical or electronic component, you can start putting a number of things in order now. First, it is useful to map out which parts of the piece of furniture may be separately regulated — think of batteries, motors or electronic controls — and to check whether a digital product passport or registration obligation already exists for that specific part under the legislation applicable to it. Next, it is practical to record which supplier supplies which component and what technical and sourcing data is already available about it, so that this information does not have to be looked up again later. After that, it is a matter of waiting: the precise requirements for the passport of the piece of furniture itself, and the question of whether and how a link between the passports is made mandatory, will follow from the delegated act for furniture once it is available. Whoever has this basis in order now will mainly have to compile the furniture passport itself later and link the existing identification data of the built-in component to it.
The basis: Article 9 and Article 12 of the ESPR
The fact that a product with multiple regulated components does not receive one passport but multiple linked passports follows from the design of the ESPR itself. Article 9 provides that the digital product passport is completed per product category via a delegated act, which means that each product category — furniture, batteries, and others — has its own passport rules. Article 12 provides for the unique identification code with which products, and the components thereof, can be identified and linked to each other. Together, these two articles form the mechanism by which separate passports of different components of the same product can be related to each other without requiring one combined passport.
If you are already making furniture with a built-in electrical or electronic component, it is best to start by internally recording the sourcing and identification data of that component, and keeping an eye on the development of the delegated act for furniture to know when and how that link needs to be made in practice.
This is based on
- Regulation (EU) 2024/1781 (ESPR), Article 9 (digital product passport)
- Regulation (EU) 2024/1781 (ESPR), Article 12 (unique product identifier)
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
A piece of furniture often consists of multiple parts, each of which may fall under a different product category: a sofa with a wooden frame, a mattress with specific upholstery, or a cabinet with integrated electronic lighting. When separate delegated acts under the ESPR apply to different parts, the question arises whether there will be one digital product passport for the whole, or multiple digital product passports that exist alongside each other. Article 9 of the ESPR (Regulation (EU) 2024/1781) regulates the digital product passport per product, and the product category-specific delegated act determines what counts as "the product". For furniture, that specification is not yet available.
Determining what the product boundary is
In practical terms, this means that a company with 10 to 100 employees must first clarify where one product ends and another begins. Is the upholstery of a sofa its own product with its own passport, or part of the passport for the sofa as a whole? That question is answered by the delegated act applicable to the product category, not by the company itself. As long as that act is not in place, there can be no certainty about how exactly it will work out for furniture. Anyone who wants to know more about how a piece of furniture is built from separate parts should read on at does each part get its own passport or the piece of furniture as a whole.
Ensuring unique identification per passport
Article 12 of the ESPR (Regulation (EU) 2024/1781) requires a unique identification code per product for which a passport exists. With multiple passports on one piece of furniture, that means multiple identification codes, each referring to their own passport. For a company, this means that internal administration — the ERP system, the article numbers, the inventory registration — must be able to handle multiple codes per assembled product, not one code that covers "the piece of furniture". How that link with an existing system can look is described at can I link the digital product passport to my ERP or inventory system.
Allowing one data carrier to point to multiple passports
If a piece of furniture consists of multiple parts subject to passport requirements, it is not practical to attach a separate QR code to each part. The question of how one data carrier on the product leads the user to the correct information — and what is needed for that in terms of linking — is precisely what GS1 Digital Link is intended for. More on this is available at what is GS1 Digital Link and do I need it for the digital product passport. For the physical implementation — where the code goes on the piece of furniture and how it remains readable — there is the page on how the QR code for the digital product passport goes on furniture.
Keeping data consistent across passports
When the same information — a material composition, a manufacturer's name, a warranty period — appears in multiple passports for the same product, there is a risk that one passport will be updated and another will not. That is not a separate legal requirement, but a practical consideration that follows directly from the existence of multiple passports alongside each other.
Where things go wrong in practice
A first situation is the sofa with a separate mattress passport: the mattress manufacturer provides a passport for the mattress, the furniture maker creates a passport for the sofa, and no one has specified which of the two is responsible for which information. In case of a correction later, no one will know anymore who is responsible for what.
A second situation is the cabinet with integrated lighting. The lighting element may fall under a different product category than the piece of furniture itself, with a different timeline for the delegated act. A company that assumes that "the piece of furniture" is sufficient discovers only later that the electronic component follows its own path.
A third situation is a series of composite products where a separate QR code is placed on the product for each component, without having given prior thought to readability and sequence. The end user scans the wrong code, or finds none of the codes logically placed.
A fourth situation is a change that is only implemented in one place. A supplier modifies the material information of a component, but the product passport of the composite furniture is not updated. For the process of correcting data that has already been published, there is the page can I modify data after the product passport has already been published.
A fifth situation is unclear who manages the product passport of a supply component when that supplier changes or stops on the market. What happens to a passport if the responsible party no longer exists is explained at what happens to the product passport if my company stops.
What you can put in order now
- An overview of the components of the composite furniture, with the question for each component whether it has its own passport or whether it is part of the passport of the whole.
- The unique identification codes that belong to each passport, including a note which system — your own ERP or that of a supplier — manages that code.
- Agreements with suppliers about who maintains which data in which passport, and how a change at one party is communicated to the other.
- A documented choice about the physical placement of data carriers on the product, especially when multiple passports must be accessible via one or via separate QR codes.
- A note in which language or languages each passport is offered, especially if components from different suppliers from different countries are involved — see in which language must I provide the product passport of my piece of furniture.
- A reference to the registration of each passport in the European register, so that it is clear where each passport can be found — explained at what is the register of digital product passports and what must I enter in it.
As long as the delegated act for furniture has not been published, it is not possible to say with certainty how the product boundary for furniture is exactly drawn. What can already be done: map your own product structure, so that this question can be quickly answered as soon as the rules become concrete.
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.