The most common mistake we see is that companies assume the provider of a furniture passport is automatically the same party as the manufacturer. That is not self-evident. The role of provider is about who places or sells the furniture under their own name on the European market, and this can just as well be an importer, a distributor under their own brand, or a project manager who has furniture assembled.
The consequence of this confusion is twofold. Some companies think the obligation does not apply to them because they are 'not a manufacturer', while others assume that a supplier further down the chain will take care of everything. Both assumptions can result in no one in the chain actually collecting the data and having the passport drawn up.
The mistake in practice
The confusion usually arises with companies that do not produce themselves, but are the face of the product. Think of an importer who has office furniture made outside the European Union and sells it under its own brand name, or a project manager who has furniture assembled according to their own specifications and then delivers it to a client. In both cases, the question 'who is the provider here' may have a different answer than seems intuitive.
A recognizable example
A furniture maker outside the EU supplies chairs to a Dutch importer. That importer puts its own brand label on them and sells the chairs on to a project manager, who in turn delivers them to an office. Which of these three parties is responsible for having the passport drawn up depends on who actually places the product on the market under which name, not on who physically made the furniture. These types of chains are more common than exceptional in the furniture industry, precisely because private labeling and own brand marketing are standard practice.
Why this mistake occurs so often
The term 'provider' is new to most entrepreneurs. What is well known is the distinction between manufacturer, importer and distributor from existing rules on product safety and CE marking. It is then tempting to assume that the role distribution for the digital product passport follows exactly the same pattern as for those earlier rules. However, the regulation has its own role classification, and a party can fulfill a different role for one product than for another. A party that purely purchases and resells for one product line can for another line be the one who actually places the product on the market under its own name.
What the regulation describes
The regulation distinguishes different roles in the chain, and links the obligation to have the passport drawn up to who is responsible for placing the product on the market, not to who physically manufactures it. For furniture, the precise implementation has yet to follow: according to the European Commission's work plan, the delegated act for furniture is expected around 2028, and this date is not yet fixed. Once that act is published, it will also become clearer how the role distribution for furniture specifically will be worked out. Until then, it is useful to read the existing definitions carefully once more the definitions carefully once more, so that you know what questions you can ask yourself and your chain partners.
How to avoid this mistake
The most practical step is not to appoint one fixed role for your entire company, but to check per product line who fulfils which role. If you carry your own brand over purchased furniture, there is a real chance that you will be designated as a supplier yourself, even if you do not produce anything yourself. If you purchase furniture under the brand of another party and sell it on unchanged, the role distribution may be different. It helps to discuss this question explicitly with your suppliers and to record in contracts who supplies which data and who is responsible for having the product passport drawn up. Supervisory authorities and the official text of the regulation remain the appropriate place for a ruling on your own situation; other companies face similar questions, and the overview of frequently asked questions shows how these are often formulated.
What this means for your next step
Do you want to know what such a product passport will look like in concrete terms and how we process that data into a product passport, then you will find that overview on our website. And if you are not yet sure which role is likely to fit your company, it is often quicker to see than you think: with the free quick-scan you can see in a few questions where your company stands, without having to create an account first.