What does a supervisory authority ask for during an inspection of furniture?

What you concretely have to do

What is expected of you

A market surveillance authority's inspection revolves around one central question: can you demonstrate that a furniture product is what it claims to be, and can the manufacturer or importer be held accountable for it? Regulation (EU) 2019/1020 governs how this surveillance is structured, and Article 27 of the ESPR (Regulation (EU) 2024/1781) describes which obligations specifically rest with the manufacturer. For a company with 10 to 100 employees, this amounts to a number of concrete points.

Keep technical documentation available

The manufacturer must be able to provide technical documentation showing that the product meets the requirements. In practice, this means that a file must exist per product or product group: material composition, test results where relevant, and the substantiation of the claims made in the product passport. For a mid-sized furniture company, this is often the first bottleneck, because this information is currently scattered across purchasing emails, supplier declarations and loose PDFs rather than in one clear file.

Make it demonstrable who is responsible for what

Article 27 establishes that the manufacturer is responsible for conformity, even if components have been purchased from suppliers. A surveillance authority does not only ask about the end product, but also about the chain behind it: who supplied the fabric, who the frame, and on what information was the composition in the passport filled in. This requires agreements with suppliers that go beyond a price agreement — data must also be exchanged that will hold up under inspection.

Have contact details and identification in order

Products must be traceable to a responsible party, with name, address and a way to reach that party. This may seem trivial, but with importers who work through multiple channels, or with private label constructions, this is often not clearly documented. A surveillance authority that wants to remove a product from the market wants to know in one step who is liable.

Be able to take corrective measures

When a product is not in conformity, the surveillance authority expects the manufacturer or importer to take action themselves: modify, remove from the market, or recall. Regulation (EU) 2019/1020 gives the surveillance authority the power to enforce this, but the first step is usually expected from the company itself. This requires an internal process: who decides, within what time is action taken, and how is the rest of the chain (retailer, project planner) informed.

Cooperate with the investigation

Regulation (EU) 2019/1020 empowers surveillance authorities to request documents, take samples and request access to business premises. In practice, this means that a company must designate someone who can handle such requests, and that the requested documents must be available within a relatively short timeframe — not only after a search through three email addresses.

Where things go wrong in practice

A number of situations regularly come up with companies facing these questions for the first time.

First: the technical documentation does exist, but has never been compiled. There is a test report on the fabric, a certificate from the foam supplier and an email about the wood type, but no one has ever brought this together into a file per article number. In an inspection, it then takes days to gather everything, while the surveillance authority expects a clear answer.

Second: responsibilities between manufacturer and importer are not clearly agreed. An importer sometimes assumes that the foreign manufacturer manages the documentation, whereas Article 27 of the ESPR actually places responsibility with the person who places the product on the EU market. That misunderstanding only comes to light when it is already too late.

Third: with collections containing many variants, data is not maintained per variant. One colour or fabric variant may have a different composition than another, but in practice, work often proceeds with a single "average" data sheet. Those encountering this issue will find further guidance in how do I create passports for a furniture collection with many colour and fabric variants.

Fourth: existing product databases are not adapted to what a supervisory authority specifically wants to see. An ERP or PIM system often already contains substantial data, but not in the form that must be demonstrable and traceable. See on this matter can I use my existing product database for the product passport.

Fifth: there is no internal agreement about who responds when a supervisory authority actually submits a request. The request lands at the sales department, who forwards it to someone who is on holiday, and valuable time is lost before substantive action is taken.

What you can put in order now

A number of matters can be put in order with relatively limited effort, and pay for themselves at the moment an actual request arrives:

• A file per product or product variant with material origin, test results and supplier declarations, bundled in one place instead of scattered across mailboxes.
• Written agreements with suppliers on which data they provide and how that data is maintained in the event of changes to composition.
• An internal designation of who is responsible for contact with a supervisory authority, including a succession arrangement.
• An established procedure for corrective measures: who decides on recalls or modifications, and how is that communicated to customers.
• Current contact details of the responsible manufacturer or importer, consistently indicated on product, packaging and in the product passport.

Those wishing to set this up now, even without the obligation already being definitive, will find a practical approach in what can I already do while the rules are not yet definitive. And for those who still need to determine whether this is relevant for their own products, a good starting point is does the digital product passport apply to my furniture.