What can I do now while the rules are not yet final?

What you concretely have to do

The delegated act for furniture has not yet been adopted, which means that the precise requirements — what data, what data carrier, what exemptions — are not yet fixed. This is not a reason to wait. The ESPR itself (Regulation (EU) 2024/1781) already provides guidance on the direction, and part of the work that will later be needed can already be done now without anticipating the final rules.

What is expected of you

Gaining clarity on your own product information

Article 18 of the ESPR describes how the European Commission prioritises product groups and draws up the work plan. For a furniture manufacturer or importer, this means above all that it is clear that furniture is on the agenda, not exactly what will later be asked of them. From a practical standpoint, this is the moment to take stock of what information about materials, composition and origin of components already exists within the company, and what is still missing. For a company with 10 to 100 employees, this information is often scattered across procurement, production and the occasional supplier — bringing it together is in itself a task that takes time, regardless of when the obligation comes into force.

Making arrangements with suppliers in the chain

Article 38 of the ESPR addresses requirements for actors in the supply chain: it states that parties in the chain may have obligations to provide information needed for the product passport. For a furniture manufacturer that does not itself produce fabric, foam or fittings, this means that their own passport obligation will later depend on what suppliers provide. Engaging in conversation with suppliers now about what data they can supply — and in what form — prevents this dependency from coming to light only at the moment when the first passports actually have to be drawn up.

Reviewing existing systems

Many companies already have some form of product database, ERP system or article registration. These systems are rarely built with a product passport in mind, but often already contain some of the building blocks: article codes, material specifications, supplier data. It is now possible to see which fields already exist and which are structurally missing. Anyone asking themselves can I use my existing product database for the product passportwould be wise to ask that question now rather than when the deadline becomes concrete.

Insight into the scope of your own product range

For furniture makers and importers with many variants — colours, fabrics, dimensions — the question of how a passport per variant is set up is a separate challenge. This question is separate from the question of when the obligation comes into force: the complexity of how do I create passports for a furniture collection with many colour and fabric variants can already be thought through now, and the result — for example, whether a separate passport is needed per variant or one passport with variants within one structure — helps in making a realistic assessment of the effort required.

Where things go wrong in practice

A number of situations come up in practice more often than expected.

Waiting until the date is fixed. Companies postpone all preparation until the delegated act is published, and then discover that collecting material data from dozens of suppliers alone takes months.

No overview of the company's own supplier chain. Especially in companies that procure components from multiple parties — foam from one, fabric from another, frame from a third — it is not always clear who can provide what information and who cannot. That gap only becomes visible when data is actually requested.

Assumptions about what already complies. An existing quality certificate or an existing product specification is taken to be something that "is surely good enough" for the passport, without having checked what data a passport will actually need to contain.

Unclear who in the chain is responsible. When importing furniture from outside the EU, there is uncertainty about whether the importer, the manufacturer outside the EU, or another party in the chain must provide the data — a question that relates to article 38 of the ESPR, and which without clear advance agreements leads to delays as soon as it becomes mandatory.

Inventory decisions without taking future requirements into account. Decisions about phased-out collections or showroom models are made without considering whether and how that stock can still be sold later. If you're thinking about this now, you'll find starting points at what do I do with furniture stock that's already there when the rules take effect.

What you can put in order now

Even without definitive rules, it is possible now to set down a number of things on paper, so that the transition to a mandatory passport will require less work when the date is actually fixed:

• An overview of the current assortment, per product line and per variant, with the materials and components incorporated in them.
• A list of suppliers per component (fabric, foam, wood, metal, fittings), with a note on which supplier can already provide material information and which cannot.
• Agreements with suppliers about data sharing, even if it is not yet known in what exact format this will have to be in later.
• An inventory of the existing product database or ERP system: which fields already exist, which are missing.
• An initial estimate of the costs that preparation and future implementation will entail — a benchmark for this can be found at what does a product passport for furniture cost.
• A note on the status of phased-out or old collections, so that inventory decisions are not disconnected from the passport obligation later.

For companies that prefer to follow a fixed step-by-step plan instead of setting up an inventory themselves, there is an overview at how do I tackle the product passport for furniture step by step. As soon as the delegated act is published and the date is confirmed, it will be indicated here when does the product passport become mandatory for furniture.