How does the QR code for the digital product passport get onto my furniture?

What you concretely have to do

What is expected of you

A data carrier that meets technical requirements

Article 11 of the ESPR (Regulation (EU) 2024/1781) states that the product passport must be accessible via a data carrier — in practice for furniture usually a QR code. That code must lead to the actual passport data, and the way this is technically set up must meet a number of conditions that will be further specified in delegated acts per product group. For a furniture company, this means above all that the QR code is not just a link that looks "good enough", but a technical element that must work in a specified manner. Many companies therefore leave this part to a platform like ours, because the technical setup of the data carrier is separate from the content of the passport itself. Whether a QR code based on a standard such as GS1 Digital Link is required depends on the precise requirements that are still to follow — what is GS1 Digital Link and do I need it for the product passport? goes into more detail on that.

A link with a unique identification code

The QR code itself is nothing more than a reference. What it refers to is a record that is linked to one specific product or one specific product group, depending on how the manufacturer has set it up. Article 11 expects that a product is recognisable and traceable via the passport. For a furniture maker who produces hundreds of variants of a chair or cabinet, this means that there must be a system that gives each unit — or each product variant, depending on the setup — its own code that cannot be confused with another. How this is set up in practice is described on how do I give each product a unique identification code?

Physical application to the product or packaging

Article 11 assumes that the data carrier is applied to the product itself, to the packaging, or to the attached documentation — the exact location will be further specified per product group. For furniture this is practically a choice between a sticker, a burned-in or engraved label, a hang tag, or a print on an attached document. For a company of 10 to 100 employees, this means a production step that must be fitted in somewhere in the process: after the final check, before packing, or when applying the existing nameplate. Furniture consisting of multiple parts — a sofa with a separate frame and upholstery, a cabinet delivered in loose modules — raises the question of whether one code for the whole is sufficient or whether parts need their own code. That issue is addressed on does each part get its own passport or the furniture as a whole?

Distinction with the label

Articles 16 and 17 of the ESPR deal with labels — an element different from the product passport, with its own rules about what must be stated and how to prevent labels from being counterfeited. A QR code for the product passport and an energy or sustainability label can appear on the same product, but are not legally the same thing. For a furniture manufacturer, the practical consequence is that an existing label or sticker on a piece of furniture does not automatically also serve as a data carrier for the passport — those two must be assessed separately from each other, even if they are later combined on one and the same sticker.

Where things go wrong in practice

An office furniture manufacturer prints the QR code as standard on the packaging, but not on the furniture itself. Once the packaging is discarded — often within a week of delivery — access to the passport for the user is lost, even though the passport still exists online.

A kitchen manufacturer uses the same QR code for each series, based on the assumption that "one passport per model" is sufficiently specific. In the event of a recall of one production batch, it is impossible to determine which units are precisely affected, because the code does not differentiate between batches or individual units.

A chair manufacturer has the sticker with QR code printed by the subframe supplier without agreeing on who is responsible if the code becomes unreadable over time due to wear or moisture. No one has then documented what should happen if a customer reports that the code no longer scans — see also what must I do if the QR code on a piece of furniture becomes unreadable.

An importer of garden furniture applies the QR code as a loose printout on the product without taking into account exposure to sun and rain during transport and storage. Within a few months, the code on part of the inventory has already faded before the product reaches the end user.

A project furnisher orders furniture from different manufacturers for one large interior project and assumes that the QR codes from each supplier are mutually interchangeable or set up in a comparable way. In practice, each code refers to a different system, with a different data structure, which at handover leads to confusion about which product passport belongs to which component.

What you can put in order now

• An internal agreement on the point in the production process at which the QR code is applied, and by whom that is checked.
• The choice of type of data carrier (sticker, engraving, hang tag, documentation) per product line, including the reason for that choice given the use conditions of the furniture.
• An overview of which unique identification code is linked to which product or product variant, so that traceability remains possible in the event of a recall or complaint.
• Agreements with suppliers or subcontractors who apply a sticker or label themselves, on who is responsible for the quality and readability of the QR code.
• A documented procedure for the situation in which a QR code is damaged or becomes unreadable for the end user, including how a replacement carrier can be provided.
• Documentation of the link between the QR code and the underlying system in which product passport data is managed, especially when that system is linked to an existing ERP or inventory system — see can I link the product passport to my ERP or inventory system?
• An overview of which language or languages are offered on the data carrier and in the underlying product passport, aligned with the countries where the furniture is sold.