must I have my passport data checked by an independent party

Not yet established for furniture

For furniture, it has not yet been established whether an independent third party must verify the passport data before it is published. The ESPR (Regulation (EU) 2024/1781) places responsibility for the accuracy of the data with the manufacturer or, for imports from outside the EU, with the importer (Article 27). Whether, in addition, mandatory verification by an independent third party is required — such as a notified body, a conformity assessment body, or an accreditation-like assessment — will be determined for each product group in a delegated act. For furniture, that act does not yet exist, and therefore there is no answer to the question of whether, and by whom, such verification will be mandatory in the future.

What does and does not fall under this question

This question concerns specifically a mandatory pre-market verification by an external, independent body — not the due diligence that a manufacturer or importer must in any case exercise. That responsibility for correct, up-to-date and complete data is already established and follows directly from Article 27 of the ESPR. This is different from mandatory audit or certification by a third party. Market surveillance is also a separate matter: Regulation (EU) 2019/1020 governs how supervisory authorities can check and take action after publication, but that is post-market surveillance, not a mandatory pre-market assessment as meant in this question. And the question of whether test methods and measurement procedures must be reliable and reproducible (Article 39 of the ESPR) is also separate from the question of who may apply or verify those methods.

Date not yet established, what is already established

There is no date to be given for when mandatory independent verification for furniture takes effect, because that obligation does not currently exist in product-specific rules. The delegated act that must establish the requirements for furniture — including any requirements on verification — is expected around 2028 according to the ESPR work plan 2025-2030. What is already established until that time is the general approach from the ESPR itself: the manufacturer or importer is responsible for the accuracy of the data (Article 27), and methods to test, measure or calculate product properties must be reliable, accurate and reproducible (Article 39). It is also already established that circumvention of the rules and artificial degradation of performance are not permitted (Article 40). Once the delegated act for furniture is published, it will be stated here whether it includes a requirement for verification by an independent third party.

What this means in practice

For anyone who wants or needs to work with a passport now, the most practical approach is to build on their own due diligence, rather than waiting for a verification requirement that still needs to be established. This starts with getting the data in order that the manufacturer itself produces or receives from suppliers: which data must be requested from a furniture supplier is a logical starting point, followed by a way to verify that supplier data is correct before it enters the passport. This is not the same as a mandatory external audit, but it is the kind of internal control that is useful in any case, regardless of what a future delegated act will require. Anyone already recording data in contracts with suppliers may consider also establishing agreements on the source and reliability of that data; see how the supply of passport data is established in a supply contract. This makes it easier to demonstrate later, if a verification requirement does apply, where the data comes from and on what basis it was prepared. For anyone sourcing furniture or components from outside the EU, there is also the question of how data from a foreign supplier is reliably obtained; this is addressed in requesting passport data from a supplier outside the EU.

The legal basis: Articles 27, 39 and 40 of the ESPR

The responsibility for the accuracy of passport data lies with the manufacturer or importer under Article 27 of the ESPR (Regulation (EU) 2024/1781), which governs the obligations of manufacturers. Article 39 of the same regulation stipulates that test, measurement and calculation methods must be reliable, accurate and reproducible — a requirement that concerns the quality of the underlying data, but does not prescribe who may apply or must verify those methods. Article 40 prohibits circumvention of the rules and artificial degradation of performance, which likewise concerns the reliability of data without imposing a third-party verification obligation. Any obligation for independent verification for a specific product category such as furniture would have to follow from the product-specific delegated act, which does not yet exist. Market surveillance after publication of the passport is regulated in Regulation (EU) 2019/1020, but this is, as stated earlier, not a mandatory prior assessment.

What to do now

Organisations now collecting passport data are well advised to structure that process in such a way that the origin and accuracy of each data point is traceable — not because external verification is already mandatory, but because this forms the basis to which any verification requirements will align once the delegated act for furniture is published. This page will be updated as soon as that act is published and it becomes clear whether an independent party will actually play a role.