What do I do with furniture stock that is already in place when the rules come into effect?

No obligation currently applies to existing stock

Furniture stock already in the warehouse or with the importer is currently subject to no obligation whatsoever to provide a digital product passport, simply because that obligation for furniture does not yet exist. The ESPR (Regulation (EU) 2024/1781) is the framework regulation that makes it possible to set requirements per product group, but the actual requirements for furniture — including the question of from what point a passport becomes mandatory and what that means for products already manufactured or purchased — have yet to be established in a separate, product-specific measure. As long as that measure does not exist, there is no rule on stock to comply with.

This concerns furniture within the ESPR framework, not other rules

This page specifically addresses the question of whether and when existing furniture stock will fall under the upcoming passport obligation. Article 1 of the ESPR describes the subject matter and scope of the regulation: it applies in principle to virtually all physical products placed on the market in the Union, with the exception of a limited number of specifically named categories. Furniture is thus one of many product groups that could potentially fall under the system, but the concrete requirements — including any transitional provision for stock — will come only with a delegated act specific to furniture. This page therefore does not address other obligations that may already apply, such as fire safety requirements, material rules or general product safety. These are separate from the digital product passport and are not covered here.

The date is not yet set, but the work plan is

There is no established date yet on which the passport obligation for furniture will come into force, and there is therefore no established rule on what happens to stock from before that date. What is established is that the European Commission has included furniture in its work plan for 2025-2030, with a delegated act expected to be published in 2028. Article 18 of the ESPR describes how the Commission prioritises and schedules product groups for such measures — that work plan is the result. Until the delegated act for furniture is actually published, there is no legal basis for saying anything about the treatment of existing stock. Once that act is in place, the precise date and any transitional provision will appear here.

What a manufacturer or importer can do concretely now

The first step is simply to establish that no action is currently required for furniture stock; there is no law to comply with as long as the delegated act does not exist. The second step, for those who wish to follow this issue, is to maintain basic data on current stock — production date, batch or order number, materials used and suppliers — because this type of data is typically needed as soon as a passport obligation does come into force, regardless of whether there is a transitional provision for existing stock. Delegated acts under the ESPR generally contain an entry-into-force date and sometimes a separate provision for products already placed on the market before that date; how and whether this will be filled in for furniture is not yet known. The third step is to monitor the publication of the delegated act for furniture itself, because that text — and not the framework regulation — is where this type of transitional question will be answered. Anyone who already organises data on materials, origin and composition will at least be in a better position when the requirements do become concrete, whatever form they take.

The basis: Article 1 and Article 18 of the ESPR

That furniture may fall within the scope of the digital product passport system follows from Article 1 of the ESPR (Regulation (EU) 2024/1781), which establishes the subject matter and scope of the regulation in general terms. That the specific requirements per product group are set separately and in phases follows from Article 18 of the same regulation, which governs the prioritization and planning of those measures and forms the basis for the work plan in which furniture is included. A specific provision regarding the treatment of existing stock upon entry into force does not appear in these two articles nor anywhere else in the framework regulation; that belongs in the delegated act for furniture yet to be published.

Those wishing to follow this subject would be well advised to begin now with putting basic data on materials and origin of their own stock in order, and to monitor this page for when the delegated act for furniture is published — only then will it become clear how existing stock is handled.

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 are now building up or holding inventory, you face a practical question: will a product passport eventually apply to furniture that is already in the warehouse, or only to what is produced after the effective date? The ESPR does not regulate this subject with a concrete transitional rule for existing inventory; Article 1 of the ESPR (Regulation (EU) 2024/1781) describes the subject matter and scope of the regulation in general terms, and Article 18 of the ESPR (Regulation (EU) 2024/1781) concerns the prioritization and planning of product groups — that is, the order in which furniture and other product categories come into scope, not what happens to already produced or imported pieces at the moment the obligation for furniture takes effect. For that specific turning point, no delegated act for furniture has yet been published; it still needs to be adopted.

Knowing when the obligation for furniture takes effect precisely

Without a published delegated act, there is no fixed date to base inventory planning on. For a company with 10 to 100 employees, this means that procurement and production planning currently stands on uncertain ground: no one can yet say whether a batch produced this year will still be "old" when the obligation takes effect or will already fall under the new rules. In practice, this means that monitoring announcements around the delegated act for furniture becomes a standing task for someone within the company, just like keeping track of other regulatory changes. More about the expected timeline is at when does the product passport become mandatory for furniture?.

Assessing whether your own furniture will fall under the obligation in the future

Not every piece of furniture needs to fall under a future obligation in the same way or at the same time; product groups are prioritized separately according to Article 18 of the ESPR (Regulation (EU) 2024/1781). For a company that operates multiple lines — for example office furniture alongside residential furniture — this means that one line may come into scope earlier than the other. This makes inventory policy per product group more meaningful than one rule for the entire assortment. A first assessment of what will and will not fall under the future obligation is at does the digital product passport apply to my furniture?.

Documenting what is already known about a product

Regardless of the precise effective date, it is practical to already keep data on materials, origin and composition of produced or imported batches. For a mid-sized company, this means that the information that will eventually have to go into a passport does not have to be dug out later from old purchase orders and supplier emails. What is practical to do now for this is described at what can you do now while the rules are not yet final?.

Deciding what to do with existing inventory if sales stall

If inventory that was already produced before an effective date sells more slowly than planned — for example because a collection is being phased out — the question arises whether that inventory is still permitted to be destroyed or whether other rules will apply to its disposal. That subject affects not only the product passport but also waste regulations and rules on the destruction of unsold products, and is addressed separately at may I still destroy unsold furniture inventory?.

Where things go wrong in practice

An importer orders a large batch of chairs from a regular supplier in Southeast Asia, with delivery taking a year or longer. By the time the batch arrives, a delegated act has meanwhile been published — but no one in the company has been following this, so the batch arrives at the dock without any preparation.

A manufacturer of office furniture maintains a large seasonal inventory of a sofa that is sold year-round. Because production happens in phases, no one knows precisely which batch was made before and which after a possible implementation date — the inventory administration does not maintain that distinction, even though that distinction may prove relevant later.

A project furnisher purchases furniture in bulk from various suppliers for a large office project that is delivered in phases. The first phase is delivered before a possible implementation date, the final phase after — but the contract with the supplier makes no distinction, making it unclear who is responsible for any product passport information in the later delivery.

A small furniture company decides, as a precaution, to rapidly sell off the entire existing inventory before an expected implementation date — based on a date the company read somewhere online, which does not match an actually published delegated act. The clearance sale is then for nothing, or worse: premature.

A manufacturer keeps no production date evidence whatsoever per batch, because that was never necessary before. If a distinction later has to be made between inventory from before and after the implementation date, there is no conclusive evidence of when which items were produced.

What you can put in order now

An overview per product group (for example office furniture, seating, tables) of the expected prioritisation, so that it is clear which product line is expected to be addressed earlier according to Article 18 of the ESPR (Regulation (EU) 2024/1781)
Production dates and batch numbers per inventory batch, so that it can later be demonstrated when a specific batch was manufactured
A fixed moment (for example per quarter) to check whether a delegated act for furniture has been published, and who within the company performs that check
Agreements with suppliers and importers on who keeps which product information, especially for batches with a long lead time
Contractual arrangements for phased project delivery on who is responsible for product passport information in later deliveries
A file per product line with material and origin data, so that data does not have to be traced back later — see also what can be done about this in practice at what can you do now while the rules are not yet final?
A note with assortment decisions (clearance, wind-down of a collection) that indicates which source an expected implementation date is based on, to avoid premature or unnecessary steps

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.