Whether the obligation for the digital product passport applies to your company depends on three things: what role you play in the supply chain of a furniture product, whether the type of furniture you manufacture, import or sell falls under the scheme, and whether the precise rules for that furniture type have already been established. For none of these three is there currently a simple yes or no answer that is the same for every company.
The regulation is primarily directed at whoever places a product on the European market: the manufacturer or the importer. Someone who only resells furniture, rents it or installs it at a customer's location is in a different position than someone who manufactures a product themselves or brings it in from a country outside the EU. These positions are designated with specific terms in the regulation, and which role applies to your company also determines whether and what obligations arise.
Your place in the supply chain matters
An installation company that installs office furniture at a client's location, an importer who stocks chairs from Asia, and a manufacturer who produces tables themselves: these are three different positions in the same supply chain. The regulation distinguishes between who is responsible for placing a product on the market and who only passes the product along or uses it further down the supply chain. This distinction is not cosmetic: it determines who must provide the data for the passport and who will have to work with it in practice once the passport exists. In the knowledge base with explanations per situation this distinction is further explained, including the question of when a company with multiple roles at the same time may be involved, for example if it both imports and assembles itself.
Not every piece of furniture is yet subject to the same rules
The regulation is a framework. Which product groups are subject to which specific requirements is being worked out per group in a separate delegated act. For furniture, this elaboration has not yet been published; the European Commission's work plan mentions 2028 as the expected time for this, with the obligation itself expected around 2030. Both dates are not yet fixed. This means that today it cannot be said with certainty which categories of furniture — office furniture, seating furniture, project furnishings, bespoke furniture — will later be subject to which exact requirements. Companies that already supply project furnishers or the government sometimes notice that clients are anticipating the regulation in their purchasing conditions, and that is another reason to think about it now than the legal obligation itself.
When you will certainly have to deal with it, and when not yet
There is a difference between being legally obliged and being wise to prepare. As long as the delegated act for furniture has not been published, there is no concrete obligation for your products to provide a passport. Once that act is in place, it will apply to which products, from which moment and with which data a passport is required. For the question of whether this applies to your specific products and your specific role, the official text on EUR-Lex remains the starting point, possibly supplemented by advice from a lawyer or the competent supervisory authority. This article describes the framework as it currently stands, not how it will concretely play out for your company.
What you can already do with certainty
Regardless of the exact date, it is already worthwhile for many companies to map out which data on materials, origin and composition of their furniture is actually available at this time, and where that information should come from if it is asked for tomorrow. This is not a legal step, but a practical one: many companies only discover during such an inventory how much of that information already exists somewhere, scattered across purchasing, production and suppliers. With a few questions you will get in five questions insight into where your company currently stands, without any obligation attached to it.
If you wonder how furnipas.eu compiles and keeps the information on this site up to date, you can read about it on the page about how the information on furnipas.eu is created. Answers to other frequently asked questions about scope and roles are bundled on the page with answers to questions we often receive.
If you want to know whether your own situation already has any connection to the regulation, the free quick-scan is a low-threshold first step. It does not provide a legal opinion, but does provide an indication with which you can start the conversation internally or with your advisor.