Rules & regulation
Digital product passports for furniture: what small makers need to know
Updated · 7 min read
Search for "digital product passport furniture" and you will find a lot of urgent advice. Much of it comes from companies selling passport software, and it tends to blur three different things: what the law already says, what the European Commission plans to do, and what nobody knows yet. For a one to three person workshop, the difference matters, because only the first creates obligations.
This guide sets out the current position from the primary sources: the Ecodesign for Sustainable Products Regulation (ESPR), the Commission's 2025 to 2030 working plan, and the Commission's digital product passport pages. It ends with a short list of things you can do now at little or no cost.
Last checked: 30 October 2026. This is general information, not legal advice.
Key takeaways
- The ESPR, Regulation (EU) 2024/1781, entered into force in July 2024 and creates the legal framework for digital product passports in the EU.
- The regulation sets no passport duty for furniture on its own; requirements apply product group by product group through delegated acts.
- The Commission's working plan, adopted on 16 April 2025, gives 2028 as the indicative timeline for adopting furniture measures.
- A delegated act cannot normally apply until at least 18 months after it enters into force, although the regulation allows earlier dates in duly justified cases.
- The data fields, the data carrier and the treatment of one-off and made-to-order pieces for furniture have not been decided.
- Keeping good records of materials, suppliers, serial numbers and care information costs little and will help whatever the final rules say.
What the ESPR and the digital product passport are
The ESPR is an EU regulation that lets the Commission set ecodesign requirements for almost any physical product placed on the EU market. Those requirements can cover durability, repairability, recycled content and the information that has to travel with a product. It was published in the Official Journal on 28 June 2024 and entered into force on the twentieth day after publication.
The digital product passport is one of the tools the regulation creates. Under Article 9, once a delegated act requires a passport for a product group, products in that group can only be placed on the market if a passport is available. Article 10 says the passport must be linked through a data carrier to a persistent unique product identifier, and that the carrier must be on the product, its packaging or its accompanying documents, as the delegated act specifies.
The Commission also had to set up a central registry of passport identifiers by 19 July 2026. It announced on 20 July 2026 that the registry is live. The registry stores identifiers and related metadata; the product data itself stays with the business or its service provider.
How requirements reach a product group
The ESPR is a framework. Article 4 empowers the Commission to adopt delegated acts that set the actual requirements for each product group. For the passport, Article 9 says each delegated act will specify, as appropriate:
| Decided in each delegated act | What it means for furniture |
|---|---|
| Which data goes into the passport | Not yet set |
| Which data carrier is used, and where it sits | Not yet set |
| Whether the passport is at model, batch or item level | Not yet set |
| Who may read which data, and who may update it | Not yet set |
| How long the passport must stay available | At least the expected lifetime of the product, per Article 9 |
The Commission's digital product passport FAQ is direct about this: there is no general obligation for a product to have a passport, and inclusion of a product group in the working plan does not automatically mean it will get one. An impact assessment comes first.
On timing, Article 4(4) says the date of application of a delegated act "shall not be earlier than 18 months from its entry into force", except in duly justified cases or when an existing act is amended. The same paragraph tells the Commission to give businesses enough time to comply, taking particular account of SMEs and microenterprises.
Where furniture stands
Article 18(5) of the ESPR named "furniture, including mattresses" among the product groups the first working plan had to prioritise. The Commission adopted that plan on 16 April 2025 as COM(2025) 187. In its table of new products, furniture appears with an indicative timeline for adoption of 2028. Mattresses are listed separately, with 2029.
Putting the pieces together gives a rough outer frame. If a furniture delegated act were adopted in 2028 and the standard minimum applied, its requirements would not apply before some point in 2029 or 2030. That is our arithmetic from the two sources, and it rests on two assumptions that may not hold: that the 2028 date is kept, and that no earlier application date is justified.
Decided, planned and unknown
| Status | Item | Source |
|---|---|---|
| Decided | The ESPR is in force and creates the passport framework | Regulation (EU) 2024/1781 |
| Decided | Passport duties apply only through product-group delegated acts | Articles 4 and 9 |
| Decided | Delegated acts normally apply at least 18 months after entry into force | Article 4(4) |
| Decided | The EU passport registry is operating | Commission news, 20 July 2026 |
| Planned | Furniture measures, indicative adoption 2028 | Working plan COM(2025) 187 |
| Planned | A mid-term review of the working plan in 2028 | Commission Green Forum, July 2026 |
| Unknown | Which data fields a furniture passport would contain | Not yet drafted |
| Unknown | Whether furniture passports would be per model, batch or item | Not yet drafted |
| Unknown | How bespoke, one-off and made-to-order pieces would be treated | Not yet drafted |
| Unknown | Any specific relief for micro and small businesses | Not yet drafted |
On the last point, the regulation does contain general support measures. Article 22 says the Commission should, where appropriate, accompany delegated acts with digital tools and guidance for SMEs, and that Member States should help SMEs comply, including through one-stop shops. None of this amounts to an exemption, and whether a furniture act will contain one is unknown.
What makers can sensibly do now
None of the following requires buying software, and all of it is useful to you and your clients regardless of regulation.
Keep material and supplier records
For each piece, note the species, the board or sheet goods used, the supplier, and any certification the supplier states on the invoice. Keep the invoices. Add finishes, glues and hardware with their product names. If a future act asks for material composition, you will already have it. If it does not, you will still be able to answer a client who asks where the walnut came from.
Give every piece a serial number
A simple, permanent number such as 2026-017 ties the piece to its records. Article 10 of the ESPR links passports to a persistent unique product identifier, so a habit of numbering every piece is a sensible base. Our guide to maker's marks, serial numbers and QR codes covers numbering schemes and marking methods.
Write down care and repair information
Note the finish, how to clean it, how to refresh it, and which parts can be repaired or replaced. A printed care card is easy to produce with our care card tool. Care and repair information is the kind of content the ESPR is concerned with, and clients value it now.
Keep records where you can find them in ten years
Article 9 says a passport must remain available for at least the expected lifetime of the product. Whatever the final rules, records that disappear when you change laptops are of little use. A simple, backed-up folder per piece is enough.
A voluntary passport is a client-service choice
Some studios already give clients a page for each piece with its materials, care instructions and history, sometimes linked from an engraved code or a certificate of authenticity. That can be good service. It does not make you compliant with a furniture delegated act that does not yet exist, and the final rules may require specific fields, formats or carriers that a voluntary page does not use. If you offer one, describe it to clients as a record of their piece, and do not present it as meeting a legal requirement.
A separate regulation: EUDR
The EU Deforestation Regulation (EUDR) is a different law with its own obligations, mainly due diligence showing that covered commodities, including wood, were not produced on recently deforested land. The Commission lists furniture among examples of derived products. Its application dates have been amended twice. As of the date of checking, the Commission's EUDR page gives 30 December 2026 for large and medium operators and for micro and small operators already covered by the EU Timber Regulation, and 30 June 2027 for other micro and small operators. Whether you count as an operator, and what you must do, depends on your role in the supply chain. Check the Commission's EUDR page before relying on any date.
Sources
- Regulation (EU) 2024/1781 (ESPR), EUR-Lex: Articles 1, 4(4), 9, 10, 13, 18(5) and 22; publication on 28 June 2024 and entry into force on the twentieth day after
- Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025-2030, COM(2025) 187, EUR-Lex: adoption on 16 April 2025, furniture listed with indicative timeline for adoption of 2028, mattresses 2029
- Digital product passport: explore our FAQs, European Commission: no general obligation to have a passport; inclusion in the working plan does not automatically mean a passport; data carrier set per product group
- The Digital Product Passport Registry is now live, European Commission: registry launch on 20 July 2026 and what it stores
- The ESPR moves into implementation, Green Forum: first priority product groups and mid-term review in 2028
- Regulation on deforestation-free products, European Commission: EUDR application dates and furniture as an example of a derived product
Questions this guide gets asked
Do I need a digital product passport for a table I sell this year?
No EU furniture rule requiring one exists yet. The Commission's own FAQ says there is no general obligation for a product to have a digital product passport; the duty only arises once a delegated act for that product group applies. Check again if a furniture delegated act is adopted.
Will commissions and one-off pieces be exempt?
Nobody can say yet. The ESPR lets each delegated act decide whether a passport applies at model, batch or item level, and the furniture act has not been drafted or published. Treat any claim about exemptions for bespoke work as speculation until the text exists.
Is the 2028 date fixed?
No. The working plan lists 2028 as an indicative timeline for adoption of furniture measures, and the Commission's FAQ notes that inclusion in the plan does not automatically mean a product will get a passport. Plans of this kind can move, and an impact assessment comes first.
Does the EU registry that went live in July 2026 mean I must register now?
The registry is infrastructure for product groups whose rules already apply. Registration duties follow from the delegated act for each product group, and there is none for furniture yet.
Should I pay for a passport platform now to be ready?
There is no compliance reason to spend money on this today, because the furniture data fields and technical requirements are not set. Good records cost little and will be useful whatever the final rules say. A voluntary passport is a reasonable choice if your clients value it.
Does EUDR apply to furniture makers?
The EU Deforestation Regulation is a separate law with its own obligations, and the Commission lists furniture among examples of products derived from covered commodities. Whether and how it applies to you depends on your role and size. Its dates have already changed twice, so check the Commission's EUDR page.