What data must I request from my furniture supplier?
Material, origin and repair data form the core
At a supplier of furniture components, wood, fabric, foam, fittings or other components, information is usually requested about the composition of the material, its origin, the presence of substances of concern, and the possibilities for repair, disassembly and recycling. This is the core of what will eventually be included in a digital product passport for furniture. A furniture manufacturer or importer does not draw up the passport from scratch themselves: that person is dependent on what the links ahead of them in the chain supply. A supplier of particleboard, textiles, metal legs or adhesive systems has data that the manufacturer themselves cannot measure or verify, such as the exact chemical composition of an adhesive or the origin of a wood species. This information must therefore be obtained at the source, and preferably well before a passport actually has to be delivered.
For whom this is relevant, and for whom it is not yet
This question applies to furniture manufacturers, importers and project furnishers who purchase from suppliers within or outside the EU, and who are ultimately responsible for compiling the product passport. The obligation to provide data within the chain rests with "actors in the supply chain" within the meaning of Article 38 of the ESPR (Regulation (EU) 2024/1781) — these are the parties that supply raw materials, parts or semi-finished products to the person who puts the final product on the market. This does not apply to the end consumer, and also not to small suppliers that fall entirely outside the scope of the later delegated act for furniture — which companies those are exactly depends on the thresholds laid down in that act, and those are not yet in place. This discussion further concerns only the question of which data are requested within the chain, not the question of who ultimately publishes or hosts the passport; that is a separate obligation that rests with the manufacturer or importer itself.
When this must happen is not yet fixed
No delegated act for furniture has yet been published, so a concrete date by which this data must be supplied does not currently exist. What is clear, however, is the framework within which that act is drawn up: the ESPR itself is in force, and Article 38 already obliges supply chain actors in general to provide economic operators with the information needed to comply with product requirements and the digital product passport, once those requirements have been established for a product category. For furniture, that moment has not yet arrived. Until that time, there is no legal obligation to request or provide data in the context of the product passport, and it therefore makes no sense to specify an exact date that is not based on anything. Once the delegated act for furniture has been published, that date will be mentioned here.
What this means for purchasing practice
In practice, it is useful to inventory now which suppliers provide which components and materials, and to check with each supplier whether they already maintain or can provide data on material composition, origin and substances used. A logical sequence is: first map out which materials and components are used in your own furniture, then check with each supplier what documentation already exists (think of safety data sheets, wood certificates, material specifications), and then engage with suppliers who cannot yet provide structured data. Article 10 of the ESPR provides an indication of the categories of information that a digital product passport must contain, such as data on performance, material composition, presence of substances of concern, and possibilities for repair, disassembly and recycling. These categories provide a useful starting point for asking suppliers now what they have available, even though the exact set of mandatory data for furniture has not yet been determined. Those who start early will prevent the submission of a passport later from stalling because a supplier cannot produce the requested data or cannot provide it within a reasonable timeframe.
The legal basis: Article 38 and Article 10 of the ESPR
That data must be supplied within the chain follows from Article 38 of the ESPR (Regulation (EU) 2024/1781), which imposes obligations on actors in the supply chain to provide the economic operator placing the product on the market with the information necessary to comply with the applicable requirements. What information this concretely entails is aligned with the categories set out in Article 10 of that same regulation, which describes the general requirements for the content of the digital product passport. Both articles are formulated generically and only apply concretely to furniture once the product-specific delegated act has been adopted.
Those who want to start now should best start with an overview of their own suppliers and the materials they supply, and maintain that overview until the delegated act for furniture provides clarity on the exact data fields.
This is based on
- Regulation (EU) 2024/1781 (ESPR), Article 38 (requirements for actors in the supply chain)
- Regulation (EU) 2024/1781 (ESPR), article 10 (requirements for the digital product passport)
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
A furniture manufacturer or importer who must compile a product passport is dependent on the data supplied by the supply chain. The ESPR regulates in Article 38 that actors in the supply chain make available the information necessary to comply with the obligations under the regulation, and Article 10 describes what data a product passport must contain. What this means in practice for a company with 10 to 100 employees breaks down into a few separate obligations.
Requesting data on materials and composition
A passport must provide insight into the materials that a piece of furniture consists of. This means that the supplier of, for example, sheet material, textiles, foam or metal parts is asked what the exact composition is, including any additions such as adhesives, coatings or flame retardants. For a company that works with fixed suppliers, this is a one-time matter of asking; when purchasing the same component from different parties, this becomes a recurring task, see what do I do if I purchase the same component from different suppliers.
Requesting origin and certificates of origin
In addition to composition, it is about origin: where was the material extracted or produced, and through which intermediate steps did it reach the supplier. For wooden components, this is a particular point of attention, because the origin of wood often goes through multiple links before it reaches the furniture maker, see how do I document the origin of the wood. For a mid-sized company, this means that not only the direct supplier is questioned, but also whether that supplier itself has origin information from its own suppliers.
Requesting data on repair, spare parts and end of life
A product passport also contains information that is relevant for the later life phase of a piece of furniture: availability of spare parts, repair options and disposal at the end of life. This is information that is not always routinely maintained by a supplier, and therefore must be actively requested, with the indication that this is part of the data required for the passport.
Data from subcontractors and suppliers further up the chain
Not only the direct supplier provides data; parties that supply semi-finished products to that supplier may also have relevant information. The question of whether a subcontractor that only supplies a component or semi-finished product must also provide passport data is unclear for many companies, see must a subcontractor supplying semi-finished products also provide passport data. For a company that itself assembles from purchased components, this means that the question "who supplies what" is carefully mapped out before data is requested.
Requesting data from suppliers outside the EU
When purchasing from outside the EU, an additional layer comes into play: the party that imports the piece of furniture or the components is the one responsible for making passport data available, even if the actual manufacturing takes place outside the EU. What this concretely means for imports from outside the Union is described on what does the product passport mean if I import furniture from outside the EU, and the way data from a non-EU supplier is requested is on how do I obtain passport data from a supplier outside the EU.
Where things go wrong in practice
A number of situations regularly occur with companies requesting data from their suppliers for the first time.
A supplier provides only a product sheet with marketing text, without the technical composition required for the passport. The buyer then incorrectly assumes that this satisfies the request.
A supplier of wood can name the wood species, but not the origin to the level that is necessary. This is often only discovered when the passport is already being compiled, rather than at the time of purchase.
When purchasing the same component from two or three suppliers, it is assumed that one inquiry is sufficient, while each supplier is contacted separately because the composition may vary per batch.
A supplier outside the EU does not respond or responds incompletely to a request for data, and the company has no alternative plan because no written agreement on data delivery was ever made.
A semi-finished product is purchased from a party that does not consider itself a "supplier of furniture components", as a result no data is requested, even though the component ends up in the final piece of furniture.
What you can put in order now
- An overview per supplier of which data has already been received and which is still missing, including material, origin and information about repair or end of life.
- A fixed questionnaire that is sent to every new supplier, so that the inquiry does not have to be reinvented each time.
- An agreement in the procurement contract on the delivery of product passport data, including the moment when this data is delivered; see how do I record the delivery of product passport data in my procurement contract.
- A procedure for the case where a supplier does not or incompletely responds, see my supplier does not provide the data — what can I do.
- A note on how the received data was checked for accuracy, see how do I check whether my supplier's data is correct.
- A file per wood species or wood batch with the certificates of origin as provided by the supplier.
- An overview of which components are purchased from which party, including subcontractors that supply semi-finished products.
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.