I sell furniture under my own brand — what obligations do I get?
Whoever puts their brand on the furniture is considered the manufacturer
Whoever sells furniture under their own brand is in most cases subject to the same obligations as the manufacturer who actually produced the furniture. This is the principle set out in Article 27 of the ESPR (Regulation (EU) 2024/1781): it is not the party that physically produces the furniture that is decisive, but the party under whose name or brand the product is placed on the market. If you sell furniture produced by another party, but affix your own brand name to it, responsibility for the digital product passport shifts to you. You must therefore obtain the underlying production information from your supplier, even though you will subsequently be registered as the manufacturer.
Who this applies to, and who it does not
This concerns anyone who places furniture under their own name or brand on the EU market, regardless of where the furniture is produced. Think of a retail chain that has furniture made by a factory in another country and sells it under its own house brand, or a project furnisher that has furniture produced and supplies it under its own name to a client. In those situations, the party that holds the brand comes forward as a manufacturer within the meaning of the ESPR.
It does not apply, or at least applies differently, to a pure reseller who leaves the brand of the original manufacturer intact. Whoever purchases furniture and resells it without changing the brand is typically a distributor, not a manufacturer — that is a different role with different obligations. The distinction therefore does not lie in who made the furniture, but in whose brand it reaches the end user under.
No fixed date yet, but a clear direction
When this obligation becomes concrete for furniture is not yet established. The ESPR itself is in force, but the product-specific requirements — including the point at which the digital product passport for furniture becomes mandatory — must still be determined via a delegated act. According to the European Commission's work plan for 2025–2030, that delegated act for furniture is expected around 2028, with a platform that anticipates an obligation around 2030. This is an expectation based on the current work plan, not an established date. Once the delegated act is published, it will be clear when the obligation for furniture comes into effect and what exactly must be included in the passport.
Until then, nothing changes in the day-to-day sale of furniture under your own brand. It is however useful to know now that the allocation of roles — who is the manufacturer and who is not — is already established in the ESPR itself. This allocation of roles will not change when the delegated act arrives; only the content and the effective date of the obligation will then become concrete.
What this means in practice
Anyone selling furniture under their own brand would be well advised to first map out which manufacturers or suppliers the furniture comes from, and what technical and material data are already available there. This is the basis on which a product passport will later be built, and this basis is often missing in private-label constructions because the brand holder itself is not involved in production.
A second step is to establish agreements with suppliers about the delivery of that data, preferably before a delegated act makes it mandatory. A supplier who does not hold the brand does not have to deliver a passport itself to the end user, but the brand holder does need the underlying information. Contractual agreements about which data will be supplied, in what form and with what timeliness, prevent that question from arising only at the moment when the obligation is already in effect.
A third point is to monitor when the delegated act for furniture is published. From that moment onwards, it will be clear which data must be included in the passport, who compiles the passport and what deadlines apply. Until then, preparation is mainly a matter of getting information in order, not of requesting or submitting anything.
Where this follows from: Article 27 ESPR
The basis for all of this lies in Article 27 of the ESPR (Regulation (EU) 2024/1781), which governs the obligations of manufacturers and also indicates when a party that does not itself produce is still considered a manufacturer — namely when a product is placed on the market under its name or brand. This article applies to products in general that fall under the ESPR; for furniture specifically, the product-specific implementation must still follow via a delegated act.
What you can do now
Map out which suppliers actually produce the furniture under your brand, and begin building a file with the material and production data that they can already provide. Agree with those suppliers on who provides which information once it is needed. Keep an eye on the publication of the delegated act for furniture, as it will determine from which point onwards and with what content the product passport for own-brand furniture becomes mandatory.
This is based on
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
What is expected of you
If you sell furniture under your own brand, you are generally considered a manufacturer under the ESPR — even if the furniture is assembled elsewhere. This is not a matter of how you describe yourself on the invoice, but of who puts the brand or trade name on the product. Article 27 of the ESPR (Regulation (EU) 2024/1781) sets out the obligations for manufacturers, and those obligations follow the brand, not the factory floor. If you are unsure whether this applies to your case, it is further explained on the page about whether you are classified as an importer or a manufacturer under the ESPR.
Ensuring that the product meets the requirements
The manufacturer is responsible for ensuring that the furniture complies with the requirements applicable to that product category under the ESPR, including the information that must appear in the digital product passport. For a business with 10 to 100 employees, this usually means that someone — often from procurement or quality — becomes responsible for requesting and assessing the correct technical and material data from the party that actually manufactures the furniture. This data does not automatically come with the invoice; it must be actively requested and checked.
Preparing and retaining technical documentation
The manufacturer is expected to ensure that the technical documentation underlying the requirements is available and retained. In the case of private label, this documentation is often held by the external producer, while the responsibility for retaining and being able to produce it rests with the brand that places the product on the market. This difference between "who has the data" and "who must be able to show it" is precisely where private label often gives rise to uncertainty, and is further explained on the page about who must provide the passport data for private label furniture.
Providing the product passport and data carrier
The manufacturer ensures that the product is accompanied by the digital product passport and by a data carrier (such as a QR code) through which that passport can be consulted. For a business that sources from an external producer, this means a choice must be made: have the passport compiled by the producer, by yourself, or by a platform that processes the producer's data into a passport. Who is precisely responsible for that step within the supply chain is described on the page about who is responsible for the product passport for furniture.
Name and contact details on the product or packaging
Manufacturers are expected to place their name, registered trade name or brand and contact address on the product, the packaging or accompanying documentation. For a brand that has multiple producers manufacture for it, this means that this information must be consistent, even if the underlying production location changes.
Corrective measures for non-conformity
When a manufacturer has reason to believe that a piece of furniture does not meet the requirements, he is expected to take corrective measures or, if necessary, withdraw the product from the market. In the case of private label, the practical implementation of this is often sensitive, because the brand is responsible to the market, while the cause of a problem — an incorrect material percentage, missing fabric composition — may lie with the producer.
Cooperation with checks by authorities
Manufacturers cooperate when a competent authority requests information or documentation. For a brand that does not produce itself, this means that there must be arrangements in place for how quickly and in what manner the producer provides that information, so that the brand itself can respond in a timely manner.
Where things go wrong in practice
A common situation is that a brand assumes that the producer "will handle the passport", without this being documented anywhere — with the result that nobody actually does. Another situation is that a brand uses multiple producers for the same product line, and the material data per supplier differs slightly, while the passport shows one product name and one set of data. It also happens that a brand has an existing piece of furniture adapted — different upholstery, different finishing — without realizing that this could have implications for the question of whether the brand itself qualifies as the manufacturer of that specific product; that subject is elaborated on the page about whether adaptation of an existing piece of furniture makes you the manufacturer. Furthermore, things go wrong when a brand only asks itself after an inspection or complaint who is actually liable for an error that the producer made in the supplied data — a question that could have been answered beforehand, and which is described in more detail on the page about liability for incorrect supplier data in the passport. Finally, confusion arises among brands that think older collections are excluded, while the question of whether that is the case can differ per product group.
What you can put in order now
- A written agreement with each producer about who supplies the technical documentation and material data, in what format and by what date.
- A fixed contact point at the producer for questions from a supervisory authority, including an agreement on response times.
- An overview per product line of which producer makes which variant, so that material data are not accidentally mixed between suppliers.
- A procedure for what happens if a producer is changed: who checks whether the new data match what is already in the passport.
- A template for requesting data from the producer, so that the same information in the same format is received each time.
- A documented agreement on liability between brand and producer in case data prove to be incorrect afterwards.
- An overview of which pieces of furniture were already brought to the market before any possible obligation, in case the question arises whether the product passport applies to them — see the page about whether the product passport also applies to furniture already on the market.
.
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.