how do I record data on textiles and upholstery in the product passport

Textiles and upholstery are material data per component

Upholstery — the upholstery fabric, filling, foam, any coatings or impregnations — is recorded as material information, just as it is for wood, metal or plastic. There is no separate regime for textiles: it concerns a component of the furniture whose composition, origin and properties must be described just as precisely as any other material processed into the product. What this concretely entails depends on what the delegated act for furniture will then precisely require, but the line from the ESPR is clear: information about materials is one of the core components of the digital product passport.

For upholstered furniture, not for loose textiles

This approach applies to upholstery and filling that are a fixed component of upholstered furniture: sofas, armchairs, upholstered chairs, bed bases with upholstery. It does not apply to loose textile products that are not attached to furniture, such as cushions, blankets or loose covers sold separately — these may fall under a different or no product passport, depending on how the product group is defined in the delegated act. It is also not yet established whether upholstery must be registered as a separate "component" or as a whole with the rest of the furniture; that choice will be made in the implementation per product group and is separate from the general obligation under the ESPR to include material information.

The rules for furniture do not yet exist

No delegated act for furniture has yet been published, and therefore it is not yet established which data on textiles and upholstery will precisely be required. The ESPR itself (Regulation (EU) 2024/1781) provides in articles 5 to 7 the framework for ecodesign and information requirements, and in article 10 the requirements for the digital product passport as a carrier of that information — but the implementation per product group, including upholstered furniture, will only follow with the delegated act. Until then, there is no legal obligation to record textile and upholstery data in a passport. Those currently dealing with upholstery can use this to already get an overview of what is known about their own upholstery fabrics, without a deadline attached to it yet.

Start with your upholstery fabric suppliers

The practical sequence starts with the upholsterer or the supplier of the upholstery fabric: what fibre composition does the fabric have (cotton, polyester, a mix), has a coating or impregnation been applied, and what filling does it contain (foam, feathers, fibres)? This data is often already available via the fabric supplier, but is not always fixed at the level of the individual furniture model — this is precisely where a product passport brings change, because it asks for this information to be linked per product rather than only per fabric batch.

A second point to watch out for now is whether the upholstery or filling contains substances that fall under a threshold value or reporting obligation, such as certain flame retardants or chemical impregnations. This overlaps with the question which hazardous substances must I mention in the product passport of a piece of furniture — upholstery fabrics are one of the places where such substances are relatively frequently found, for example in foam fillings or in fabrics with a flame-retardant finish.

A third point is the question of whether upholstery must be registered as a separate component. Furniture are composite products with multiple materials, and the way this is recorded per component is detailed on the page about must I record the material for each component of a piece of furniture. Upholstery and filling are thereby an obvious separate component, distinct from, for example, the frame or legs, although the exact classification is not yet fixed.

Those who have upholstery replaced or repaired — for example new upholstery on an existing frame — will also have to deal with the question of how such an intervention is reflected in the passport; that subject is described on the page about record repairs of a piece of furniture in the product passport.

Finally, it is practical to now inventory which data about textiles are business confidential, such as a specific fabric recipe or supplier name, and which data must actually be public. That assessment is not specific to textiles, but upholstery is a category where supplier information is often considered commercially sensitive.

The legal basis: articles 5 to 7 and article 10 of the ESPR

The obligation to include material information — including that on textiles and upholstery — in a product passport follows from articles 5 to 7 of the ESPR (Regulation (EU) 2024/1781), which establish the basis for ecodesign and information requirements per product group. Article 10 of the same regulation describes the requirements for the digital product passport itself, as the carrier on which that information is made available. Both articles are formulated in general terms and apply to all product groups; the specific implementation for furniture, including upholstery, follows from the delegated act that has not yet been published.

Anyone wishing to see which data categories are generally expected in a furniture passport will find an overview on the page about which data are included in the product passport for furniture. For upholstery, it is advisable to contact the fabric supplier early about fibre composition, filling and any treatments, so that those data are available once the delegated act for furniture provides clarity on what exactly must be recorded.