What is a digital product passport for furniture?

What you concretely have to do

What is expected of you

A digital product passport is, according to Article 9 of the ESPR (Regulation (EU) 2024/1781), a collection of product data that can be retrieved via a data carrier (usually a QR code) and that remains linked to that single product throughout the entire lifespan of the product. For furniture, this concretely means that in future there will be a code on or attached to a cabinet, chair or desk behind which information about materials, origin, repair and recycling is concealed. Article 10 of the ESPR describes what those data and the manner in which they are accessible must comply with. What this means in practice for a furniture company breaks down into a number of separate obligations.

Make a passport available per product

The obligation is not to upload a pdf to the website once, but to ensure that per product (or per product model, depending on how the future rules determine this) a passport exists that can be called up via the data carrier. For a company with 10 to 100 employees, this means a different way of working than the current product information on an invoice or in a catalogue: the passport must be findable and up-to-date per delivered item or per batch, not only at the first sale but as long as the furniture is in use. Which furniture exactly falls under this obligation is described on the page on which products from the furniture industry fall under the ESPR.

Attach a data carrier to or with the product

Article 9 requires a physical or digital carrier — in practice a QR code — that is attached to the product itself, to the packaging or to the supplied documentation. For a production company, this means an adjustment in the production process or in logistics: there must be a moment when the code is linked to the specific item and attached in a durable manner, even for furniture that remains in use for years or changes hands.

Keep the data up to date

A passport is not a snapshot. Article 10 sets out requirements for the accessibility of data during the lifespan of the product, which means that information that changes — for example about a repair service, a manufacturer that changes name, or parts that are no longer available — must be kept up to date. For a company of limited size, this is often the obligation that places the most burden on the organisation: it is not a one-time action, but a process. How often exactly that updating must take place is explained on the page on how up-to-date the data in the product passport must be.

Manage access for different parties

Not everyone who scans the QR code should see the same information. A consumer, a recycler and a market inspector have different information needs, and Article 10 provides for tiered access. For a company, this means that thought must be given to which data are publicly visible and which remain restricted for example to supervisory authorities or downstream parties in the value chain. This distinction is set out on the page on who is allowed to view which data from the product passport.

Where things go wrong in practice

A passport is created once at the launch of a new furniture model, but is not updated again when a parts supplier changes or when a product is further developed. The QR code then points to outdated information, which makes the passport practically worthless at the moment when someone actually needs it — for example during a repair years later.

Another recurring problem is that companies assume that custom-made furniture or project fitting falls outside the scheme, without having verified this. Whether and how the passport requirement applies to custom-made furniture is a question that cannot be answered self-evidently with "no"; the explanation for this is on the page on bespoke furniture and project fitting.

It is also sometimes assumed that all product data included in the product passport must also be publicly visible. This leads to reluctance on the part of manufacturers to cooperate, for fear that competition-sensitive information about materials or suppliers becomes freely available. This assumption is not necessarily correct, and is addressed on the page on business-sensitive data and the product passport.

A fourth situation: companies wait to prepare until the obligation officially takes effect, because the date has not yet been set. This is an understandable, but risky choice, because setting up a working product passport process — collecting data, linking it to products, keeping it up to date — requires more time than the period between publication of the delegated act and the actual implementation date.

Finally, things go wrong when companies with fitted furniture (think of kitchens or built-in wardrobes) assume that the construction products rules automatically take precedence over the ESPR, without verifying this. This distinction is not always as clear-cut as it seems, and is explained in more detail on the page on fitted furniture and the question of whether the construction products regulation or the ESPR applies.

What you can put in order now

• An overview per product line of which data is already available (materials, origin, composition) and which still needs to be collected.
• An internal agreement on who is responsible for keeping product passport data up to date when a supplier, component or process changes.
• A documented procedure for applying the data carrier in the production process, including the point at which the code is linked to a specific item or batch.
• A classification of data according to who may access it, so that the distinction between public and protected information is not determined ad hoc.
• Documentation on which product groups within the company's own range fall under the future regulation, including the substantiation of this — relevant for those who wish to verify whether the product passport applies to their own furniture.