How long must I keep spare parts for furniture available?

What you concretely have to do

What is expected of you

The ESPR (Regulation (EU) 2024/1781) makes it possible for specific requirements to apply per product group — including furniture — on repair and spare parts. This occurs through a delegated act, which establishes at product group level which performance and information requirements apply. For furniture, that delegated act does not yet exist. What we describe below is therefore the framework as the ESPR sets it out in Articles 5 through 7 — not a concrete deadline, because that appears nowhere in the current text.

Availability of spare parts as a possible ecodesign requirement

Article 5 of the ESPR mentions availability of spare parts as one of the aspects that can be regulated in a product group-specific regulation, along with matters such as repairability, dismantling and durability. For a furniture company, this concretely means: there is currently no legal deadline for how long spare parts (hinges, legs, upholstery fabric, mechanisms) must remain available. Once the delegated act for furniture appears, it could well establish a concrete period. A company with 10 to 100 employees is well advised to already start inventorying which spare parts of its own products are critical for repair, so that a later requirement does not come as a surprise.

Information on spare parts in the digital product passport

Article 7 regulates which information must be included in the digital product passport, and repair information — including data on spare parts — is one of the categories that applies. In practice, this means that when the furniture-specific requirements are in place, the passport will likely become a resource for information about which spare parts are available separately and through which channel. For a company that already supplies spare parts (for example replacement upholstery or frames) it makes sense to maintain that information in a structured way, rather than only upon request through customer service.

Responsibility of the manufacturer for the underlying data

Article 27 sets out the obligations of manufacturers, including responsibility for the accuracy of data that ends up in the passport. Whoever who is responsible for the digital product passport of furniture reads it will see that this responsibility does not automatically lie with the party that has the passport drawn up — this may be an importer or brand owner working on the basis of manufacturer data. For the question about spare parts, this is relevant: whoever supplies the data on spare parts is also responsible for ensuring that data is correct at the moment the requirements become concrete.

Where things go wrong in practice

A number of situations come up repeatedly among furniture companies preparing for this:

• Spare parts are not standardised. Each series gets a slightly different hinge or leg, so there is in fact no 'spare part' but only custom work per production batch. This makes future availability requirements difficult to implement.
• The information only exists at the factory, not with the party drawing up the passport. With private label or import, repair information is often not provided, because no one is asking for it yet. Whoever wants to know more about this, reads who must provide the passport data for private label furniture.
• An importer thinks the obligation stays with the manufacturer outside the EU. That is not automatically the case; see manufacturer outside the European Union for how that relationship is arranged in the ESPR.
• Spare parts are preserved, but nowhere is it recorded when a production line stops. When a model is phased out, the knowledge about which spare parts still existed often disappears together with the production documentation.
• Modifications to an existing piece of furniture (different upholstery, different frame) are not seen as something that can shift the responsibility for spare parts. Whoever has a product refined or modified can thereby fall under a different role; this is elaborated in do I become a manufacturer if I have an existing piece of furniture modified or refined.

What you can put in order now

Even without the furniture-specific deadline already in place, it is worthwhile to introduce structure now:

• An overview per product line of which parts are designed as replaceable (hinges, legs, mechanisms, upholstery components).
• A fixed procedure for how long parts of discontinued models remain in stock internally or with a supplier, independent of what the law will eventually require.
• Agreements with suppliers on who supplies which part data and keeps it current — relevant for private label and for imports, see also am I an importer or manufacturer under the ESPR.
• A documented responsibility for the accuracy of repair and parts information, so that in case of a dispute it is clear who supplied which data — see also who is liable for incorrect data from a supplier in the passport.
• A template for parts documentation that already aligns with the categories in Article 7 of the ESPR, so that insertion into the product passport later is a matter of submission rather than starting from scratch.

Once the delegated act for furniture has been published, with a concrete deadline for the availability of spare parts, we will further develop this section with the precise period and the conditions that apply to it.