Whoever places a piece of furniture on the market is not automatically the "manufacturer" according to the regulation. The text distinguishes three roles: the manufacturer, the importer and the distributor, and each role carries a different responsibility for the digital product passport. For example, a director of an installation company who has furniture produced under their own brand can be considered a manufacturer, even if they have not tightened a single screw themselves.
In short: the manufacturer is whoever designs the furniture or has it made and places it on the market under their own name, the importer is whoever brings the furniture into the EU from outside, and the distributor is whoever sells or supplies the furniture further without being a manufacturer or importer. Which role you fulfil determines which part of the passport you must be able to provide and who is ultimately responsible if something is missing.
Why this distinction matters
The digital product passport must contain data on materials, origin and repair options of a piece of furniture. That data must come from somewhere, and the regulation specifies where it starts. The manufacturer is usually the one who provides most of the data, simply because they have the furniture made and therefore have access to information about raw materials and the production process. The importer and the distributor have a lighter, more controlling role: they must check whether the passport exists and whether it is correct, not make up the content themselves.
For an office manager ordering office chairs from a supplier outside the EU, this means that their own company may be classified as an importer, with its own set of obligations, even if no part has been designed in-house. Anyone unfamiliar with this distinction risks placing responsibilities with the wrong party, or conversely, assuming that someone else will take care of it.
What the regulation expects per role
The manufacturer typically compiles the technical documentation and ensures that the passport is included with the furniture before it leaves the factory. The importer checks whether that passport is actually present and remains accessible, and acts as the first point of contact within the EU if the manufacturer is established outside the Union. The distributor, often a wholesaler or retailer, does not need to draw up the passport themselves but must be able to flag if it is missing or clearly incorrect before the furniture is sold on.
This division is intended to prevent responsibility from falling between the cracks. At the same time, it means that one company can fulfil multiple roles at the same time, and that in practice things are often less clear-cut than the definitions suggest. For a clear overview of what a role means in practice, you will find it in the explanation per situation in the knowledge base.
What if your company fulfils multiple roles
A project furnisher who both has furniture produced themselves and purchases from third parties can be a manufacturer for one piece of furniture and a distributor for another. The regulation looks at each product, not at each company, to determine which role applies. This makes it important to clarify per product line who plays which role, rather than making one assumption for the entire range.
Because this classification directly affects what must be included in the contract with a software supplier or supply chain partner, it is advisable to address this distinction early in the conversation. With a few questions you can see which role fits your situation, without that immediately creating an obligation.
Where you will find this in practice
The definitions of manufacturer, importer and distributor are set out in the official text of the regulation, together with the accompanying explanation of when each role applies. Furnipas.eu uses that source text as its starting point; here you can read where our information comes from. For translating this into the day-to-day practice of a specific company, it remains advisable to consult a lawyer in case of doubt or to contact the competent supervisory authority, especially when a company operates in multiple EU countries.
Are you in doubt about which role applies to your company, or would you like to read the frequently asked questions about this first? View the frequently asked questions on roles and responsibilities, or take the free quick-scan to see in a few minutes where your situation stands.