Furniture is in ESPR's first working plan, so the furniture rules are coming. The delegated act that sets them is not written; the Commission expects it between 2028 and 2030. Certain today: a piece will need a Digital Product Passport with material, substance and durability data. Not decided: the field list, the tests, model or item level, and the date.
Key takeaways
Once the furniture act applies, expected between 2028 and 2030, a piece without a registered Digital Product Passport cannot be placed on the EU market.
The EU passport registry is linked to the customs single window, EU CSW-CERTEX. An unregistered passport is flagged at the border.
A sofa is wood, steel, foam, textile, adhesive and coating. Each material carries its own substance declaration, recycled-content figure and end-of-life instruction.
Durability tests, repairability scores and spare-part availability are expected on the passport; the thresholds are not set.
Most of the data sits with ten or more suppliers per SKU, not in your PLM. Collecting it is the work.
ESPR furniture scope: is furniture covered, and who is responsible
Who signs for the passport depends on your role in the chain. A brand that designs and sells under its own name is the manufacturer; a brand that imports finished pieces is the importer; a retailer is the distributor. Each role below carries a different duty, and the same company can hold two.
Manufacturer
Designs or manufactures the product and places it on the market under their name or trademark. Bears the full burden: must create the DPP, ensure conformity with all ecodesign requirements, and register the passport in the DPP Registry.
Importer
Places products from outside the EU on the Union market. Must verify the manufacturer has fulfilled all ESPR obligations, that the DPP exists and is registered, and that conformity documentation is available.
Distributor
Makes products available on the market but does not manufacture or import them. Must verify the product carries the required data carrier (QR code) and that storage/transport conditions do not compromise compliance.
Authorised Representative
Appointed by a non-EU manufacturer to act on their behalf. Can be mandated to handle DPP registration, conformity declarations, and cooperation with market surveillance authorities.
Obligations compared
| Role | DPP Creation | DPP Registry | Conformity Assessment | Data Carrier |
|---|---|---|---|---|
| Manufacturer | Full responsibility | Must register before market placement | Must perform and document | Must affix QR / NFC to product |
| Importer | Verify it exists | Verify registration | Verify documentation available | Verify presence on product |
| Distributor | N/A | N/A | N/A | Verify presence on product |
| Auth. Representative | As mandated | Can register on behalf | Keep documentation available | N/A |
What ESPR asks of every furniture product
Four requirement blocks apply to every product group, and the furniture act will say which fields each one carries for a chair or a sofa: the passport, substances of concern, and durability and performance.
Digital Product Passport
A structured, machine-readable dataset accessible via QR code, containing materials, origin, durability, and end-of-life data.
Substances of concern and durability for multi-material furniture
Declare all SVHCs, REACH-restricted substances, and chemicals that negatively impact recyclability or safety.
Performance standards
Minimum thresholds for durability, reparability, recyclability, and recycled content as defined by the delegated act.
What a Digital Product Passport for furniture will need to contain
Every piece under the act carries a Digital Product Passport: a machine-readable record reached from a QR code or NFC tag on the product, registered in the EU registry before the piece is placed on the market. The expected fields, with their legal basis, are in the table.
Data fields expected for furniture
| Data Category | Required Information | Legal Reference |
|---|---|---|
| Product Identity | Unique identifier (ISO/IEC 15459), product name, model, manufacturer details | Art. 9(1), Annex III |
| Materials | Full bill of materials, fibre/material composition per component | Art. 7(2)(a) |
| Recycled Content | Percentage of recycled content per material type | Art. 7(2)(a) |
| Substances | All SVHCs, REACH-restricted substances per component | Art. 7(2)(b), Annex I |
| Durability | Test results for structural integrity, surface resistance, component lifespan | Art. 5-7 |
| Reparability | Reparability score, spare part availability, disassembly instructions | Art. 5-7 |
| End-of-Life | Disassembly guide, material separation instructions, recyclability assessment | Art. 7(2)(a) |
Substances of concern and durability for multi-material furniture
Every substance of concern in the piece has to be declared: those that affect recycling, safety or the environment. Furniture is the hard case because a single product carries six chemical families across its materials.
Substance categories that matter for furniture
- Flame retardants: Brominated and chlorinated flame retardants in upholstery foam, textiles, and plastics
- Formaldehyde: Used in adhesives, particleboard, MDF, and plywood: a major indoor air quality concern
- Surface coatings: VOCs in paints, lacquers, and varnishes applied to wood and metal components
- Plasticisers: Phthalates in PVC components, synthetic leather, and flexible plastics
- Heavy metals: Chromium in leather tanning, lead in pigments, cadmium in plating
- PFAS: Per- and polyfluoroalkyl substances in stain-resistant fabric treatments
The declaration is a passport field, not a marketing claim. A missing or wrong one stops the product at the border once the act applies.
Furniture ecodesign requirements: durability and repairability per piece
The furniture act is expected to set minimum levels on the parameters below. The thresholds are not written; the parameters are in the ESPR framework already.
- Durability: Structural integrity under load, surface abrasion resistance, UV resistance for outdoor furniture
- Reparability: Ease of disassembly, availability and pricing of spare parts, repair documentation
- Recyclability: Material separability, mono-material design incentives, recycling infrastructure compatibility
- Recycled content: Minimum percentages of post-consumer recycled material per component type
- Carbon footprint: Product-level carbon footprint declaration (disclosure, not yet a performance threshold)
- Manufacturing origin: Country of final assembly and key component sourcing
- Care instructions: Maintenance guidance to maximise product lifespan
- End-of-life: Disassembly guide and material recovery instructions for recyclers
Where furniture is harder than textiles
A sofa is not one product for a passport. It is a composite of five or six materials from different tiers, and the passport needs a field set for each.
One piece, several materials, one passport
An upholstered sofa has a wood frame, steel springs, polyurethane foam, upholstery fabric, adhesives, coatings and hardware. Each stream needs its own substance declaration, recycled-content figure and end-of-life instruction, from ten or more suppliers per SKU.
Wood inputs also fall under EUDR
The wood in the frame also falls under EUDR from 30 December 2026: plot geolocation and a due diligence statement per shipment. Two rules, one supplier, two evidence sets.
| Component | ESPR Requirements | Additional Regulations |
|---|---|---|
| Wood frame | Materials, recycled content, durability, substances | EUDR (geolocation, deforestation-free) |
| Metal parts | Recycled content, carbon footprint, recyclability | Iron/steel delegated act (if applicable) |
| Upholstery | Fibre composition, substances, durability | Textiles delegated act, REACH |
| Foam | Substances (flame retardants), recyclability | REACH (isocyanates) |
| Coatings | VOC declarations, substance of concern listing | REACH, Paints delegated act |
Packaging falls under PPWR
The carton, the foam and the film fall under PPWR, tracked per format and separately from the product.
The furniture delegated act: what is expected and when
Two dates are fixed, 18 July 2024 and the April 2025 working plan. The furniture act and the registry are expected, not dated; the table shows the order.
ESPR Enters into Force
Regulation (EU) 2024/1781 is published and enters into force. The framework for Digital Product Passports and ecodesign requirements is established.
First Working Plan Published
The Commission publishes its first working plan prioritising product categories for delegated acts, including furniture. Specific DPP data fields and performance parameters are outlined.
Textile delegated act expected; duties about 18 months later
Digital Product Passport requirements take effect for the first priority categories. These set the operational precedent for furniture brands to follow.
Furniture Delegated Act Expected
The furniture-specific delegated act is expected to take effect, mandating DPPs, performance requirements, and substance declarations for all furniture sold on the EU market.
EU DPP Registry and Customs Integration
The centralised DPP Registry goes live with customs single window integration (EU CSW-CERTEX). Products without a registered passport will be flagged at EU borders.
Timeline in one look
| Milestone | Date | Impact on Furniture | Legal Reference |
|---|---|---|---|
| ESPR in force | 18 Jul 2024 | Framework established; prepare data systems | Reg (EU) 2024/1781 |
| Working plan | Apr 2025 | Furniture priority confirmed; data fields outlined | Art. 18(1) |
| First delegated act | 2027 (textiles) | Passport duties about 18 months after adoption | Delegated acts |
| Furniture delegated act | 2028-2030 | DPP, performance, substances mandatory | Delegated act (TBC) |
| DPP Registry + customs | Progressive | Border enforcement of DPP compliance | Art. 13 |
The data to start collecting now
The act will fix the fields. It will not change where the data lives or who holds it. Eight things to have in place before it lands, whatever it says.
Map your product portfolio
List every SKU that will need a passport and every material in it: wood, metal, foam, textile, plastic, coating, adhesive.
Audit supplier data readiness
Ask each supplier what they can give per component today: composition, recycled content, substance declaration, test results.
Establish substance tracking
Check every component against the REACH candidate list and SCIP, starting with flame retardants, formaldehyde, VOCs and PFAS.
Build durability and reparability data
Compile the tests you have for structure, surfaces and lifespan; note spare-part availability and write the disassembly steps.
Evaluate recycled content
Record recycled content per material stream, steel, polyester, wood fibre, with the supplier certificate and chain of custody behind it.
Plan end-of-life documentation
Write the disassembly and separation guide a recycler will use, and mark which parts are recyclable, reusable or waste.
Check EUDR overlap
If the piece has wood in it, start the EUDR work now: plot geolocation, deforestation-free evidence, the statement per shipment.
Choose your DPP platform
Choose the platform that will generate, host and register the passports, with GS1 Digital Link carriers and a multi-material data model.
Furniture passports carry more fields than most product groups. A pipeline built this year is filled by the time the act names the fields.
Book a call to discuss your compliance strategyWhat the furniture act means for your team, before it is written
The risk in the furniture act is not the durability threshold. It is the number of fields per piece and the number of suppliers behind them, every season, for every SKU. One missing field and the passport is invalid; no passport and the piece stays outside the EU market.
What that means for a furniture team:
- Component data from every stream: wood, metal, foam, textile and coating suppliers each answer for their part, from a link, with the certificate attached.
- Substances checked against REACH and SCIP: per component, again when a component changes.
- Wood origin collected once: the plot data EUDR needs in December 2026 is a field on the same product record the passport will use.
- The passport published from the record: in Tappr from Passport Builder, on the GS1 Digital Link code Brand Cloud generated, registered when the EU registry opens.
The act is expected between 2028 and 2030. The supplier pipeline takes longer to build than the act takes to read. The product side is on the furniture page.