Which furniture sector products fall under the ESPR?

Furniture is in principle covered by the ESPR

Furniture is in principle covered by the ESPR because the regulation applies to physical products placed on the market or put into service, and a cabinet, chair, desk or sofa falls without exception into that category. However, the ESPR is a framework regulation: Article 1 establishes the broad scope of application, but the concrete ecodesign requirements — and with them the obligation for a digital product passport — are established separately for each product group via a delegated act. The fact that furniture falls within the scope of the ESPR therefore does not mean that concrete requirements for furniture now apply. This only follows once the European Commission publishes a delegated act for the product group furniture.

Who it applies to and which products

The ESPR is directed at those who place a product on the market or make it available in the EU: manufacturers, importers and, in certain cases, distributors. For the furniture industry, this essentially concerns seating furniture, tables, cabinets, beds and similar furniture items that are sold or supplied as physical products. Article 2 elaborates on concepts such as "product", "component" and "intermediate product", and this is relevant for furniture makers: parts that are also marketed separately — a hinge, a sheet of material, a foam filling supplied to another manufacturer — can also fall within the scope of the regulation as a component or intermediate product, even if the furniture item itself is not yet complete.

What is not covered is at least as important. Article 1 explicitly excludes a number of product categories from the scope of the ESPR, such as food, medicines and living organisms. For the furniture industry, this is generally not relevant, but it shows that the ESPR is not unlimited: it applies to physical products within the meaning of Article 2, and not to services, software as such, or categories that the regulation explicitly places outside its scope. Also important: as long as no delegated act for furniture has been established, there is no concrete obligation for, for example, a digital product passport for furniture — the broad scope of Article 1 is a necessary condition, not a sufficient condition for this.

When concrete requirements for furniture will apply is not yet fixed

No delegated act for the product group furniture has yet been published. According to the ESPR work plan 2025–2030, such an act for furniture is expected around 2028, but this is a schedule, not a fixed date. Until the moment when the act is actually published and enters into force, no concrete ecodesign requirements and no obligation for a digital product passport applies to furniture under the ESPR. Once that date is fixed, it will be updated here. Until then, the only certainty is that the ESPR as a framework regulation already exists and that furniture falls within its scope of application as described above — the details for this specific product group are still to follow.

What this means for the furniture industry

For a manufacturer, importer or fitter, the first point is to establish whether it is a physical product being placed on the EU market or put into service — with regular furniture production this is almost always the case. The second point is the distinction between the end product and its components: anyone who also supplies components or intermediate products separately to other manufacturers would do well to follow how the definitions from Article 2 will work out in practice once the delegated act for furniture is in place. The third point is the timeline: because there are no concrete requirements yet, there is no acute obligation, but the preparation time can be used usefully by gaining insight into your own material and component data now, since a future product passport will rely on that data. The fourth point is to follow the ESPR work plan: the planning in it gives an indication of when furniture will be addressed, without this being a hard commitment on the outcome or timing.

The basis: Article 1 and Article 2 of the ESPR

That furniture falls within the scope of the ESPR follows from Article 1 of Regulation (EU) 2024/1781, which establishes the subject matter and scope of the regulation for physical products placed on the market or put into service, with a limited number of excluded categories. The relevant concepts — product, component, intermediate product and placing on the market — are set out in Article 2 of that same regulation. Together, these two articles form the framework within which later delegated acts, such as those for furniture, receive their concrete implementation.

If you want to prepare now, it is best to start by mapping your own product list and the origin of materials and components, and to monitor the progress of the ESPR work plan for the moment when the delegated act for furniture is published.

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

The ESPR (Regulation (EU) 2024/1781) is a framework regulation. This means that the regulation itself does not specify per product group which furniture products exactly fall under the rules — that is done in delegated acts that the European Commission draws up per product group. Article 1 of the ESPR (Regulation (EU) 2024/1781) describes the subject matter and scope of the regulation in general terms: it concerns products placed on the market of the European Union, with the aim of making these products more sustainable, circular and energy-efficient. Article 2 of the ESPR (Regulation (EU) 2024/1781) provides the definitions that apply, such as what is meant by a "product" and a "product group".

For the furniture sector, no delegated act has yet been published that specifically designates furniture as a product group. This makes it difficult to say with certainty right now which furniture product does and which does not fall under the obligations. What can be said is: the ESPR is designed to be broadly applicable to physical products placed on the EU market, and furniture forms a logical product group within this, given the focus on circularity in the sector. More information about the structure of this legislation is available at what changes does the ESPR bring for the furniture sector?.

Checking whether a product group has been designated

A company that manufactures or imports furniture can monitor whether and when the Commission publishes a delegated act designating furniture (or a subcategory thereof, such as office furniture or seating furniture). For a company with 10 to 100 employees, this mainly means: keeping a close eye on developments, without there being a concrete obligation to act right now. How these delegated acts work exactly and why they are decisive is explained at what is a delegated act and why does it determine what I have to do?.

Assessing whether your own assortment falls within the definitions

Article 2 of the ESPR (Regulation (EU) 2024/1781) uses definitions that leave room for interpretation at the level of a product group. A company can already classify its own assortment: which products are loose furniture placed on the market, and which products are part of a building or permanently built-in? This distinction is relevant because not every furniture product necessarily falls under the ESPR — some built-in elements may fall under other legislation. See do built-in furniture products fall under the Construction Products Regulation or under the ESPR?.

Taking into account your own company size

The ESPR does not make a distinction in the framework regulation itself based on company size for the question of whether a product falls within the scope of application. However, it is conceivable that a delegated act may later contain exceptions or transitional periods for smaller market participants. As long as that act has not been published, it cannot be said with certainty. More information on this is available at does the product passport also apply to small businesses?.

Where things go wrong in practice

A few situations regularly come up in the furniture sector when companies prepare for the ESPR:

A manufacturer assumes that "furniture" as a whole forms one product group, whereas a delegated act may make a distinction between, for example, seating furniture, cabinets and tables, each with their own requirements.
An importer of bespoke furniture assumes that bespoke work automatically falls outside the rules, without this already having a basis in the published text. See also does the product passport also apply to bespoke furniture?.
A project furnisher treats a built-in kitchen or fixed wall-mounted cabinet system as "ordinary furniture", whereas the classification as a building product or furniture item has consequences for which regime applies.
A company delays all preparation until the delegated act is available, and then discovers that gathering basic data about materials and origin takes more time than expected.
An undertaking confuses the ESPR as a framework regulation with the later, product-specific obligations, and thinks that there is already an obligation for a product passport while only the legal framework exists.

What you can put in order now

Even without a published delegated act for furniture, it is practical to establish order in your own data and product range classification now:

An overview of your own product range, classified by type of furniture and by the question of whether the product is placed on the market as a standalone item or built-in.
A list of materials, components and origin per product group, as a basis for what may later be included in a passport — see also which data that are expected to be on which data will be included in the product passport for furniture?.
A note of the status of the delegated act for furniture, so that it is clear internally from which moment an obligation may arise.
Agreements with suppliers on the availability of product data, so that these do not have to be requested at the last moment.
An internal note on the classification of your own range under the definitions of Article 2 of the ESPR (Regulation (EU) 2024/1781), so that this assessment does not have to be made repeatedly once there is more clarity.

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.