You are not a furniture manufacturer and you do not resell furniture under your own name. You purchase office chairs, conference tables or office furnishings because your business needs them, or you install them as an installation company at a client's location. The question that then arises: does the furniture passport obligation also affect me?
The short answer: the regulation directs the obligation to draw up and provide the passport in principle to those who place furniture on the market as a manufacturer, importer or distributor. If you purchase furniture exclusively for your own use without offering it again yourself, that obligation usually does not rest with you. But that is not the end of the matter: as a buyer you will receive the passport, and in some cases your role moves closer to that of a market participant than you might think.
The difference between purchasing and placing on the market
The regulation distinguishes between those who first make a product available on the EU market and those who subsequently use the product. An office manager who purchases furniture for their own premises uses the product. An installation company that takes furniture from a manufacturer and places it unchanged at a customer's location does essentially the same thing: it passes the product on without offering it itself as its own supply on the market.
This changes as soon as you add something that the regulation considers relevant: have furniture supplied under your own brand, assemble it into a new product, or import it for the first time from a country outside the EU. Those who do so may indeed be considered a manufacturer, importer or distributor, with the associated passport obligations. The difference between manufacturer, importer and distributor is explained in more detail on the page about those roles; for those uncertain about their own position, that is a good starting point.
Project furnishing often sits between two roles
For project furnishers and installation companies, the situation is more nuanced than for an office manager ordering individual chairs. Those who assemble furniture into customised solutions, deliver it under their own project name, or independently source from multiple countries, may be assigned their own responsibility for the passport in the eyes of the regulation — even if the work feels mainly like the execution of someone else's design. Supervisors look at the actual role in the chain, not at the name on the invoice.
What this practically means if you only purchase
If you fall outside the core obligation, that does not mean the passport is irrelevant to you. You receive the passport as part of the delivery, and it is useful to you: it contains information about materials, maintenance, repair and end-of-life that remains relevant as long as the furniture is in use — often longer than the ten years the passport is guaranteed to be accessible. It is therefore advisable to ask when purchasing who provides the passport and how long it remains accessible, and to record that in the purchase conditions. What agreements are often overlooked in this regard can be read in the article about the most common mistake in the purchasing contract.
Even for those certain they are not a manufacturer or importer, it is useful to briefly check their own position. If you are still uncertain after reading this article whether your business has its own obligation, then a few questions will give you a first indication of your situation. This is not a legal opinion, but a practical first check before you potentially investigate further or consult a lawyer.
Where you find the rest of the picture
Whether your business is subject to the obligation is one of many questions that arise with the furniture passport — alongside questions about concepts, supervision, personnel and interaction with existing rules. An overview of those subjects, selected per situation, can be found in the knowledge bank with all topics on the furniture passport. If you want to first understand where the information on furnipas.eu comes from before you continue reading, the page on our working method explains how we keep sources and data traceable.
Ultimately, your own situation remains decisive, and this can differ per business and per contract. For an assessment of your specific position in the supply chain, the official text of the regulation, or a lawyer, is and remains the appropriate point of contact. If you want to first get an idea yourself, feel free to start with the free quick-scan or browse through the topics in the knowledge bank.