Yes, custom-made furniture and project furnishing are in principle subject to the same rules as furniture that is mass-produced. The regulation looks at the type of product and at who places it on the market, not at the question of whether one piece or a thousand pieces are made. A custom-made counter, a company restaurant full of fixed seating or a series of cabinets for one specific office building can just as well fall under the definition of furniture as a chair that is on the shelf in a store.
What matters is who in that chain acts as the party responsible for the passport. That is not automatically the installation company that places the furniture, and it is not automatically the client who has it made. It depends on who actually manufactures the furniture or places it on the market under their own name. For the exact delimitation in the case of one-off, highly personalized orders, the implementation in the delegated act yet to be published is decisive; that text does not yet exist.
What counts as 'placing on the market'
The regulation does not speak of shops or series, but of the moment when furniture is first made available on the EU market. That moment occurs just as much in the case of a unique piece for one customer as in the case of a production line. A table that is specially designed and built for a new office building is just as much 'placed on the market' at the moment of delivery as a table that is ordered from a catalogue. The quantity or degree of personalization does not change that.
What does differ is the administrative burden. With a production line, one passport is often used for an entire range of identical products. With custom-made furniture, it is obvious that each unique piece needs its own data, because materials, dimensions or finish can differ per order. That does not make the process fundamentally different, but it does make it more cumbersome to set up.
The role of the supplier in custom-made furniture
In the regulation, the party responsible for drawing up and maintaining the passport is called the supplier. With standard furniture, that is usually clear: the manufacturer or importer who places the product on the EU market first. In the case of project furnishing, that role can be less obvious, especially when several parties work together: a designer, a furniture maker, an installation company and sometimes an intermediary who coordinates the whole.
The question of who in such cooperation acts as the supplier is not something we can answer here for an individual situation. What can be said is: the role follows from the actual actions, not from the name on the invoice. An installation company that only assembles what someone else has manufactured is in a different position in the supply chain than an installation company that itself designs furniture and has it produced under its own name. Those who want to assess that difference for their own business will find the concepts and the associated explanation in the knowledge base with explanation per subject.
What this means for installation companies and project furnishers
For companies that mainly place or remove furniture, the first question is not 'must I create a passport', but 'what role do I play in this specific assignment'. That can differ per project: in one job you deliver and install what a supplier has made, in another you design and build the furniture yourself. Those who want to check that per project without immediately opening an extensive file can answer a few questions and immediately get an indication of where their own situation roughly stands.
For office managers and HR managers who primarily procure for their own use, the situation is somewhat different: they are usually not suppliers, but rather the party who will need to be able to work with a supplier's passport, for example during maintenance, renovation or disposal of the furniture. This is a different position in the chain, with different points of attention.
What is not yet established
The core of the rules, namely that furniture receives a passport and that a supplier is responsible for it, is fixed in the regulation. The precise implementation for borderline cases, such as one-off bespoke work, small editions or collaborative arrangements between multiple parties, will have to emerge from the delegated act that the European Commission is preparing. Until that is in place, it is advisable not to make assumptions about your own situation too firmly.
You can read more about how we obtain that information and which sources we use on the page where the information on this platform comes from. For your own specific position in a project, a lawyer or the competent supervisory authority remains the appropriate contact point; we can explain the rules, but we cannot assess how they will play out in a specific contract or collaborative arrangement.
Do you have doubts about whether your company, project or collaborative form falls under these rules? Run through the free quick-scan or browse through the answers to questions that other entrepreneurs have already asked to see if your situation is already covered there.