When does the product passport become mandatory for furniture?

What you concretely have to do

What is expected of you

The question "when will it happen?" has no date as an answer at this moment, and that is not an evasive answer — it is the current state of affairs. The ESPR (Regulation (EU) 2024/1781) is the framework regulation that creates the possibility to set requirements for products, including furniture. But the regulation itself does not yet impose any obligation for furniture. That obligation comes only with a delegated act that is drawn up specifically for the furniture industry. As long as that act has not been published, there is no obligation, no date and no transition period to act on.

Tracking when furniture comes into scope

Article 18 of the ESPR describes how the European Commission prioritizes which product groups receive a delegated act first. Furniture is on the radar, but the order and pace are not fixed in the regulation itself — they are filled in through work programmes that the Commission publishes periodically. For a company with 10 to 100 employees, this means that keeping track of those work programmes, or following a specialized source that does so, is more practically useful than waiting for an announcement that appears on its own. Anyone who wants to know now whether furniture will later be subject to the rules can start by asking which products of the furniture industry fall under the ESPR — that separates the product groups that are promising from those for which nothing concrete exists yet.

Understanding what a delegated act does and does not regulate

Article 4 and Article 8 of the ESPR determine the Commission's power to establish these acts and what must be included in them: among other things the product group, the requirements for sustainability and information, and the periods that apply to that specific group. This is a technical instrument, not a law in the ordinary sense — but it does have binding force once it has been established. For companies it is useful to know that the actual obligation, with a real date, only arises at the moment this act exists. Further explanation of how this works can be found at what a delegated act is and why it determines what you must do.

Making a distinction between "not yet required" and "never relevant"

An act that has not yet been published is not a guarantee that nothing will come. The planning included in the ESPR work plan points towards 2028 for a delegated act that affects furniture, with expected implementation around 2030 — but these are not established dates, they are an expectation based on current planning. Companies that already supply project furnishers or public procurement sometimes see demand for product information arise earlier than legislation strictly requires, simply because contracting parties are getting ahead of the curve. Whether that is relevant for a specific company depends on the type of product and the sales market; see whether the digital product passport applies to your furniture for an initial orientation.

Where things go wrong in practice

A number of patterns recur among companies that prepare (too early or too late) for this subject.

A supplier or industry organization mentions a year as established. That year is often the date from a work programme, not from a published delegated act. The difference is significant: a work programme is a plan, a delegated act is an obligation with a date.

A company waits with all preparation until the act has been published. That is defensible in itself, but the act may contain implementation periods immediately after publication that are short. Anyone who then still needs to find out what data is needed at all will lose time that is not available.

No distinction is made between the ESPR in general and the furniture-specific act. The ESPR now affects many product groups (textiles, electronics, construction materials); news about it is sometimes read as "the product passport is coming" without checking whether that news concerns furniture.

Internal responsibility is lacking. No one in the company is designated to monitor this topic, so the publication of the delegated act goes unnoticed for months, until a customer or competitor draws attention to it.

Built-in or customized furniture is lumped together with standard products. For project furnishers this is a recurring pitfall: a built-in kitchen cabinet may fall under a different regulation than a freestanding cabinet. See whether built-in furniture falls under the Construction Products Regulation or the ESPR and whether the product passport also applies to custom-made furniture for the nuances involved.

What you can put in order now

Even without a confirmed date, there is work that is worthwhile doing now, and that will save time later:

• An overview of the company's own product groups, with a note on which of these might possibly fall under a future delegated act. This prevents the question "does this apply to us?" from arising only when the act is already in place.
• A designated person or role within the company to monitor the ESPR work programme and announcements about furniture, on a regular basis (for example every quarter) to check on this.
• An inventory of which product data are already available from procurement, production or suppliers, and which are missing. This ties in with the question what data will be included in the product passport for furniture — a good starting point for determining what can already be collected now.
• Agreements with suppliers and importers about who provides which data, so that this is not worked out only at the time of the first obligation.
• A note on the company's own position in the supply chain (manufacturer, importer, project furnisher), because the obligations may be assigned to them differently once the delegated act is in place.

Anyone putting this in place will not come away with a complete product passport — that is also not possible as long as the requirements are unknown — but with a starting position in which the first steps after publication of the act are no surprise.