Does each component get its own passport or the piece of furniture as a whole?

What you concretely have to do

What is expected of you

A cabinet delivered in loose parts — side panels, shelves, hinges, a set of fittings — raises a question that the ESPR does not answer with a simple yes or no: does the digital product passport cover the end product as the user assembles it at home, or each component separately? The answer depends on how the product is marketed and which delegated act for furniture will subsequently lay down the precise rules. What Article 11 and Article 12 of the ESPR (Regulation (EU) 2024/1781) already establish is the system within which that choice is made.

One identification code per passport

Article 12 of the ESPR requires a unique identification code that links the product (or product category, depending on the delegated act) to the correct dataset. For a piece of furniture sold as a single assembled whole — one article number, one package, one invoice line — it makes sense for that code to apply to the whole, not to each shelf or hinge. In practical terms, for a company with 10 to 100 employees, this means the current article number system can probably serve as a basis, but you need to look carefully at what currently runs through your administration as a single sales unit. Companies struggling with setting up those codes can review the system on How do I assign a unique identification code to each product?.

Maintain the distinction between product and component

Article 11 of the ESPR describes the technical structure of the digital product passport, including the possibility that a passport refers to other passports or to components within the product. This is relevant for furniture made up of loose parts: a component can itself be a product with its own lifecycle (think of a replaceable hinge set that is also sold separately), or it can be purely a building block that exists only within the end product. For a company that sells both complete cabinets and loose replacement parts, this means that you must first establish which components have their own commercial status and which do not. That distinction determines whether you subsequently have one passport or a set of passports that refer to each other, as described on My product needs multiple digital product passports — how does that work together?.

Follow the practice of packaging, assembly and sales

What probably makes the difference is not the physical form of the product but the way it is brought to market. A piece of furniture that is sold in a flat box with assembly instructions is one product for the consumer with one purchase moment — even though it consists of twenty parts. For companies, this means that existing sales and packaging logic is an important indicator of how the passport will subsequently be structured, more so than the technical composition of the product itself.

Where things go wrong in practice

Do not code components separately if they are never sold separately. A manufacturer of dining tables registers each table top, each base and each screw set as a separate item with its own code, while customers can only order the complete table. This produces an unnecessarily large and error-prone dataset, even though no customer ever looks up the loose table top.

Forget replacement parts in the setup. A cabinet manufacturer sets up the digital product passport for the complete product, but also supplies loose hinges and drawer rails via customer service afterwards. If those components are not themselves registered separately in the system, an important reference point for repair information that should belong to the component will subsequently be missing.

Stick the QR code at the wrong level. For a modular sofa set, the QR code is only placed on the box of the main element, not on the loose corner modules that can be ordered separately. If someone later buys only the corner module, they have no access to the passport. The correct location for that carrier depends on how the product is packaged and sold, see How does the QR code for the digital product passport get onto my furniture?.

Do not include components from suppliers in the dataset. An importer of flatpack furniture does not include data on hinges and fittings because "they were not made by us", while these parts are part of the product to be assembled and thus part of the material information in the passport.

Merging two separate article numbers into one passport without substantiation. A manufacturer combines two components that are purchased separately and each have a separate article number into one passport, without documenting why this choice was made. During an inspection or when the assortment changes, it is then no longer possible to trace which information belonged to which component.

What you can put in order now

• An overview of which parts of the furniture can be sold separately or reordered, and which exist exclusively within the assembled product.
• The link between existing article numbers and the unit to which the passport will be applied — product, module or component.
• A documented decision on which components receive their own unique identification code, with the reasoning behind it, so that this choice does not remain implicit.
• Agreements with suppliers on who provides which data for components that are not manufactured in-house, including fittings, hinges and fastening materials.
• An overview of where the QR code is placed at each packaging level, especially for products that are sold both as complete units and in loose modules.
• Documentation of how data from the company's own inventory or ERP system is used to populate the passport, so that changes in composition or components take effect automatically — see Can I link the digital product passport to my ERP or inventory system? for the technical aspects of this.

This documentation is mainly intended to introduce structure now, so that when the delegated act for furniture establishes the final classification, the link to the company's own product administration is already in place.