who must provide the passport data for private label furniture

What you concretely have to do

What is expected of you

Anyone who has furniture made by a third party and then places it on the market under their own brand name is considered a manufacturer for those items. This is one of the key points of the ESPR: not the person who physically makes the furniture bears the obligations of Article 27 of the ESPR (Regulation (EU) 2024/1781), but the person whose name or brand appears on the product. This applies regardless of how much involvement there has been with the design or production. More about that distinction can be found on selling under your own brand — what obligations do I have?.

Gathering and assembling the data

Article 27 places the responsibility on the manufacturer to ensure that the digital product passport exists and is correct, even if the actual production data comes from a supply chain partner. For a company with 10 to 100 employees, this usually means there must be someone — often in procurement or quality — who requests technical specifications, material composition and origin information from the factory, checks for completeness, and passes it on to the party that compiles the passport. If you yourself know nothing about the materials because "the factory handles that", you run the risk of publishing a passport without anyone within your own company having checked whether the content is plausible.

Ensuring that the supplier cooperates

Article 38 of the ESPR (Regulation (EU) 2024/1781) describes requirements for actors in the supply chain: anyone who supplies components, materials or semi-finished products must make available the information needed to comply with product requirements. This directly affects private label, because the factory that produces the furniture for you is often the only party in that chain that actually has the source data — wood species, adhesive composition, coatings, origin of the metal in a frame. In practice, this means that there must be a basis in the purchasing contract or in correspondence with the factory to request that information and receive it in a timely manner. Without that agreement, there is a real risk that the data arrives late, is incomplete, or is not available at all when the passport is to be published.

Ensuring that the passport meets the formal and substantive requirements

Article 10 of the ESPR (Regulation (EU) 2024/1781) sets requirements for the form and content of the digital product passport itself: which data categories must be included, how the data carrier is linked to the product, and how accessibility and updates are regulated. For a private label seller, this means it is not enough to have a pdf with specifications somewhere — the data must be structured correctly and linked to a data carrier on or with the product. This is typically the part where a platform such as furnipas takes over the work, but the underlying data must first come from the manufacturer (in this case: the private label seller).

Where things go wrong in practice

A number of situations recur regularly in practice with private label procurement.

The factory supplies a technical datasheet, but not the data the passport requires. A supplier document with strength classes and dimensions is not automatically the same as the material composition or origin information relevant for a product passport. Anyone assuming that one document replaces the other often discovers too late that there is a gap in the data.

There is no contractual agreement on the supply of passport data. With many private label relationships, the purchase agreement was drawn up years ago, well before the product passport became relevant. Without an addendum that specifies who supplies which data and when, the factory is not obligated — and often not accustomed — to provide this information proactively.

The factory changes a component or material without notifying the seller. A private label seller who has requested data once and regards it as fixed runs the risk that the passport no longer matches the actual product when the factory uses, for example, a different adhesive, coating or supplier of plastic components.

Goods are purchased from multiple factories at the same time under one brand name. With private label, the same model name is sometimes produced by different manufacturers, with minor differences in material or construction. If the passport data is not maintained per production variant, there is a risk that one passport is used incorrectly for all variants.

Unclear responsibility if the factory itself also supplies directly to other parties. When the same factory also supplies the product under its own brand or to another private label customer, there can be uncertainty about who must arrange the passport for which market version. See also for the broader definition. who is responsible for the product passport for furniture?.

What you can put in order now

For a private label seller, it is practical to regulate the following points in writing, preferably as an addendum to existing purchase agreements:

• A supplier declaration in which the factory confirms which materials, components and finishes are incorporated in the product, including origin where relevant.
• An agreement on notification obligation for changes: the factory informs the private label seller as soon as a material, component or supplier changes, so that the passport can be updated.
• A fixed contact person at the factory who is responsible for providing passport data, to prevent requests from being lost between departments.
• An overview per product variant, especially when the same model is produced by multiple factories or in multiple versions.
• A note in the procurement file about when and from whom which data were received, so that in an audit it can be demonstrated that the data have a traceable origin.

For companies that are unsure whether they qualify as a manufacturer for a particular product or as something else — for example because it also involves imports — the distinction is set out on am I an importer or manufacturer according to the ESPR?. And when the factory itself is located outside the EU, there is an additional layer of obligations, which is described on my manufacturer is located outside the European Union — who arranges the product passport then?