does the product passport also apply to furniture that I am already bringing to market

No, only furniture placed on the market after the implementation date

Furniture already being sold will in most cases fall outside the obligation to hold a digital product passport — the obligation applies from the moment a furniture category is designated in a delegated act, and in principle only affects products placed on the market from that moment onwards. What stands in a showroom today or is shipped from a warehouse is therefore in principle not subject to passport requirements with retroactive effect. This is the main rule that follows from the structure of the ESPR, and this structure is more important than a single detail in this case, because the entire obligation for the product group furniture still needs to be developed.

For whom this applies, and for which products it does not

The ESPR (Regulation (EU) 2024/1781) is a framework regulation: it regulates how eco-design requirements and the digital product passport are developed, but it does not itself impose any concrete obligation on furniture. Article 1 of the ESPR describes the subject matter and scope of the regulation in general terms; which product groups are actually to be addressed and when is determined separately for each product group via a delegated act, as provided for in Article 4 and Article 8. For furniture, that delegated act does not yet exist. This means that there is currently no legal obligation to maintain a digital product passport for furniture — not even for furniture being produced or imported today.

The question "does it also apply to what I am already selling" thus actually hinges on two separate moments: the moment when the obligation for furniture as a product group takes effect, and the question of whether that obligation also applies retroactively to stock and models already on the market. Based on how the ESPR is structured, the reasonable assumption is that the obligation applies to products placed on the market after the effective date, not to products that were already circulating before that. A definitive ruling on this can only be given by the delegated act itself, because that act establishes the precise content and effective moment for furniture (Article 8, ESPR). As long as that text has not been published, this is an expectation based on the system of the regulation, not an established fact.

It is also important to note who serves as the point of contact in this question. Whether someone acts as a manufacturer, importer or only as a distributor determines who will be required to supply the data for the passport — this distinction is elaborated on the page am I an importer or manufacturer according to the ESPR?. Those who sell furniture purely for resale without being a manufacturer or importer have a different role and different obligations, described on the page about what obligations does a distributor or retailer of furniture have?.

When the obligation takes effect has not yet been determined

There is no established implementation date for furniture yet. Article 18 of the ESPR describes how the Commission prioritises and schedules product groups for the introduction of eco-design requirements and the product passport, but that article does not contain a specific date for furniture — that date must come from a delegated act. This platform is based on an expected timeframe around 2028-2030 based on the ESPR work plan, but this is a planning assumption, not a legally established date. Once the delegated act for furniture has been published, the precise date will appear here.

Until then, there is no change for ongoing sales in the legal obligation to maintain a digital product passport. This does not mean that there is nothing to do: other legislation (such as material information, safety requirements or labelling) may already apply independently of the ESPR, but this is a separate matter from the product passport itself.

What this means in practice

For anyone selling furniture now, the first step is straightforward: nothing needs to happen at this moment for the digital product passport, because the obligation for furniture is not yet in force. The second step is to determine what role someone will have later — manufacturer, importer, private label operator or only seller — because that determines who must collect and provide the data. With private label furniture, that question often does not automatically rest with the party that holds the brand; who exactly that is, is detailed on the page who must provide the passport data for private label furniture.

The third step is: to think ahead about what data will be needed later, such as material composition, origin and repair information, so that this does not have to be collected only when the date of entry into force arrives. Anyone who has models adapted or refined by a third party is well advised to check whether that has consequences for who will later qualify as the manufacturer — that is detailed on the page do I become a manufacturer if I have an existing piece of furniture modified or refined. The fourth step is: to follow the announcement of the delegated act for furniture, because only then will it become clear whether, and with what transition period, existing stock or models could still fall under the obligation.

The legal basis: Article 1, 4, 8 and 18 of the ESPR

That the obligation does not yet apply follows from the structure of the ESPR itself: Article 1 describes the scope of application of the regulation in general terms, Articles 4 and 8 give the Commission the power to establish, for each product category, via a delegated act, the concrete requirements and the date of entry into force, and Article 18 describes how those product categories are prioritized and planned. For furniture, that delegated act does not yet exist, and therefore there is no legal obligation that "furniture sold now" could fall under.

Anyone who now wants to know what happens as soon as the obligation does apply can continue reading about the consequences of the absence of a passport on the page what happens if I do not have a product passport for my furniture?, and about possible sanctions on the page what fine or sanction do I receive if I do not have a product passport. For now, the most concrete action is: to get clarity on your own role in the supply chain and to keep an eye on the publication of the delegated act for furniture.