must I record repairs of a piece of furniture in the product passport

Repair data should in most cases be included in the passport

The starting point of the ESPR is that a digital product passport is not merely a snapshot at the point of sale, but carries information about the lifespan of a product. Repair data fits this approach because it shows precisely what the regulation intends the passport to achieve: a longer useful life, less waste, and better insight into the condition of a product at any point in time. Whether and how repairs must be recorded in practice will be worked out per product category in a delegated act; for furniture, this specification is not yet available.

Who this applies to and where the line is drawn

This question applies to everyone responsible for the passport of a piece of furniture: the manufacturer or importer who has the passport drawn up, and consequently the party that carries out or has repairs carried out, such as a project furnisher who maintains office furniture. This concerns specifically repair history: when was something replaced or repaired, and by whom. This is different from information that is fixed at purchase, such as materials per component or disassembly instructions. These latter two are a fixed property of the product and do not change through use; repair data is by contrast dynamic and follows the furniture over time. Also not the same: warranty information or a service contract. These are commercial agreements between seller and buyer, not part of the statutory mandatory passport as described by the ESPR.

When this is established: not yet, the delegated act is missing

Article 9 of the ESPR describes what a digital product passport in general terms must be able to do: keep information accessible and up to date during the lifespan of the product. Article 10 elaborates on the technical and organisational requirements involved, such as who may add or modify data. Neither of these articles specifically establishes for furniture whether repair history is a mandatory field. That specification will only come with the delegated act for the furniture product category, and it does not yet exist. Until that act is published, it is not established what data on repairs exactly will be mandatory, in what form, and who must supply it. As soon as that date and content become known, this will be supplemented here.

What this means in practice for those already working with passports

Those already having a product passport drawn up would be well advised to think about how repairs could be accommodated later, without relying on that as a fixed requirement. A logical first step is to look at what is already established in the passport: which data are included in the product passport for furniture describes the basic structure, and it does not yet include a separate field for repair history. A second step is to think about who should have access later to add such data, because a repairer is not automatically the same party as the manufacturer who initially compiled the passport. That touches on the question who may view which data from the product passport, in which the distinction between viewing and adding is already partly explained. A third point to keep in mind: if repair data becomes mandatory later, it is reasonable to expect that it will be subject to the same update logic as other modifiable fields, as described in the question of how often data in the passport must be updated. For those already setting up a system to record maintenance and repairs — which is advisable in any case for warranty or liability purposes — it is not wasted effort: that record can later serve as the basis for what the passport will require, even if the form has not yet been established.

The legal basis: Articles 9 and 10 of the ESPR

That the passport has a life-cycle perspective follows from Article 9 of Regulation (EU) 2024/1781, which describes the digital product passport as an instrument that keeps data about a product available as long as it is in use, not only at the moment of sale. Article 10 of the same regulation sets out the technical requirements for that passport, including the possibility that data can be supplemented or amended after initial registration, and by whom that may happen. Both articles leave the precise implementation for specific product groups to delegated acts, as referred to in Articles 5 to 7 of the ESPR, which establish the ecodesign and information requirements for each product group. For furniture, that act has yet to be published, and therefore there is currently no article that explicitly governs the obligation to keep track of repairs in the furniture passport.

Anyone wishing to follow this subject should ensure that their internal records of repairs and maintenance are in order, and wait for the delegated act for furniture before building a fixed procedure around it. This page will be updated once that act is published and it becomes clear what exactly will apply to repair data.