How do I approach the product passport for furniture step by step?
From data collection to QR code on the furniture
The product passport for furniture is created in practice in a fixed sequence: first the data about the product is collected, then that data is compiled into a passport, and finally the QR data carrier that refers to that passport is affixed to the product or supplied with it. Article 9 of the ESPR (Regulation (EU) 2024/1781) describes the digital product passport as a collection of product data that is electronically accessible via a data carrier to everyone who has the right to access it, from supervisory authority to end-user. Article 10 specifies what such a passport must meet. For furniture makers and importers, this means that the approach begins with their own product information: which materials, which origin, which composition, which repair or recycling information is already recorded. This basis determines how smoothly the rest of the process proceeds, regardless of who ultimately compiles or hosts the passport.
Who this applies to, and who it does not
This approach is described for furniture manufacturers and importers who place furniture on the EU market, and for project furnishers who place a piece of furniture on the EU market as the first party. Article 9 and 10 of the ESPR form the general framework that will apply to product groups once that group is designated; they themselves say nothing yet specific about furniture. Those who only resell furniture without being a manufacturer or importer themselves do not usually fall under the same responsibility as the person who places the product on the market for the first time — although the role in the chain can differ depending on the situation. These steps do not cover other obligations that may exist separate from the passport, such as labelling or other product rules; this is specifically about the compilation and delivery of the digital product passport itself.
No fixed date yet, but a work plan
There is no fixed date yet for when the digital product passport for furniture becomes mandatory. The ESPR itself (article 9 and 10) sets out the general framework, but the concrete obligation for a product group such as furniture only arises through a separate, yet to be published delegated act. According to the European Commission's work plan for the period 2025-2030, that delegated act for furniture is expected in 2028; a definitive date is therefore not yet fixed. Until that act is published, there is no legal obligation for furniture to have a digital product passport — but the likelihood is growing that preparation will pay off in time, because the basic data needed for a passport is usually the same, regardless of the exact implementation date.
The steps in practice
Those who wish to make the approach concrete begin with an inventory of what product information already exists: material composition, origin of raw materials, country of production, and any information about repair, maintenance or disassembly. Next, it is useful to establish who in your own chain fulfils the role of manufacturer or importer, as this determines who will be responsible for providing the data. Subsequently, you can consider which party compiles that data into a passport that meets the form described in Article 10, and who handles the hosting and the QR data carrier — this can be done internally or through a specialised platform. A next step is to check whether your own product data can be easily kept up to date, because a passport after publication is usually not static. Finally, it is practical not to delay this preparation until the delegated act is in place: the basic data that is collected is useful even without a legal obligation for your own business operations and makes the transition to a mandatory passport later smaller.
Legal basis: Article 9 and 10 of the ESPR
This description follows directly from the ESPR (Regulation (EU) 2024/1781). Article 9 introduces the digital product passport as a mandatory instrument once a product group is designated for it, and describes its purpose: making product data electronically accessible via a data carrier. Article 10 supplements this with the requirements such a passport must meet. Both articles form the horizontal framework that applies to all product groups under the ESPR; the specific implementation for furniture — which data exactly, and from when — follows from the delegated act for this product group yet to be published.
Those who wish to start now can, without waiting for the delegated act, internally map which product data are available and which party in the chain will be responsible for supplying it. Once the delegated act for furniture is published, the precise date and content will be added to this page.
This is based on
- Regulation (EU) 2024/1781 (ESPR), Article 9 (digital product passport)
- Regulation (EU) 2024/1781 (ESPR), article 10 (requirements for the digital product passport)
The regulation itself is available on EUR-Lex. We refer per statement; you do not need to believe us.
What you concretely have to do
The delegated act for furniture has not yet arrived, but the approach itself does not need to wait for it. Those who follow the structure of Article 9 and Article 10 of the ESPR (Regulation (EU) 2024/1781) will know which building blocks will be needed later and can already prepare most of them now. This article runs through the steps as a company of 10 to 100 employees would take them in practice.
What is expected of you
Determining whether the product passport applies
Not every piece of furniture automatically falls under the first round of ESPR obligations; this will be worked out per product group in a delegated act. For a company, this means that the first step is not "create a passport", but to find out whether and for which product lines this will be required later. Anyone in doubt will find a more detailed explanation at does the product passport apply to my furniture?
Collecting and organising product information
Article 10 of the ESPR describes what types of information the digital product passport must be able to contain: data on materials, origin, repair and end of life, depending on what the product group-specific rules will require later. In practical terms, this means that a company inventories what it already knows about its products (material composition, suppliers, components) and what is still missing. With a collection containing many variants — colours, fabrics, legs, upholstery — this quickly becomes a substantial task; how that setup looks in that case is described at how do I create passports for a furniture collection with many colour and fabric variants
Linking the information to a digital carrier
Article 9 of the ESPR requires that the product passport must be accessible via a data carrier; in practice, a QR code or similar element on or with the product. For a company, this means a physical and organisational step: determining where that carrier goes on the product (label, hang tag, packaging) and how that carrier links to the correct, up-to-date passport data. This is usually not a design matter but a logistics matter: which variant gets which code, and how do you prevent a code from ending up with the wrong model.
Ensuring that the data remains current and accessible
The passport is not a snapshot; Article 10 assumes data that remains accessible throughout the life of the product. For a company of this size, this means a choice: who manages the data if a supplier changes, a material is replaced, or a product line is phased out? That is less of a legal question than an operational one: someone must be responsible for keeping it up to date.
Connecting the existing systems
Many companies already have a product database, PIM system or ERP with some of the necessary data. The question then is not whether everything needs to be re-entered, but whether the existing structure matches what the passport will need later. An overview of where that usually causes problems and where it actually works well is at can I use my existing product database for the product passport
Where things go wrong in practice
Data exists, but not at product level. A manufacturer knows which wood, which glue and which fabric are "usually" used, but not exactly which combination is in which SKU. When drawing up a passport per variant, this gap only comes to light then.
Responsibility between manufacturer and importer is not assigned. For furniture that comes to the European market via an importer, it is not always clear beforehand who supplies which data and who hosts the passport. This leads to delays as the deadline approaches.
The QR code points to a page that is not maintained. A data carrier is created when a product is launched, but no one updates the content when a material or supplier changes. The code is still correct, but the content is no longer accurate.
Variants are underestimated. A collection with ten colours and five fabric types quickly yields fifty combinations, each with its own material list. Companies that underestimate this start with a manual approach that breaks down as soon as the collection is expanded.
Waiting for the rules to be finalized. Because the delegated act has not yet been published, some companies are postponing all preparation. This means that as soon as the date is confirmed, all steps — collecting data, adapting systems, arranging carriers — must happen at once. What can already be done in the meantime is set out under what can I already do while the rules are not yet final?
What you can put in order now
- An overview per product line of which material, origin and lifespan data are already known and which are still missing.
- A list of suppliers and the data they provide, with an agreement on who communicates any changes and to whom.
- An internal agreement on ownership of the passport data: who updates the content if a material, colour or supplier changes.
- A categorization of variants (colour, fabric, size) that aligns with how the data carrier will later be assigned per variant, particularly relevant for larger collections.
- An overview of the existing product database or PIM system with a note on where the structure already aligns with what a passport needs and where it does not.
- An estimate of the costs associated with preparing, hosting and managing passports, as a basis for internal decision-making; guidance on this is available under what does a product passport for furniture cost?
- A note on what a supervisory authority could reasonably ask during an inspection, so that internal preparation is aligned accordingly; see what does a supervisory authority ask during an inspection on furniture?
None of these points need to wait for the final date. Together they form the foundation which, as soon as the delegated act is available, only needs to be supplemented with the specific requirements that will then apply.
This is not legal advice. This page provides general information about the legislation that this platform concerns. We do not know your situation. If in doubt about your own case, consult a lawyer or the competent supervisory authority.
Written with AI based on the sources above, reviewed by a human on 2026-08-22. Is something wrong? Let us know — corrections take priority.