ESPR and the Digital Product Passport for Furniture: What Is Decided, What Is Planned and What Suppliers Will Be Asked For

What the ESPR is, and what it is not

Regulation (EU) 2024/1781, the Ecodesign for Sustainable Products Regulation or ESPR, entered into force on 18 July 2024. It replaced the Ecodesign Directive, which only covered energy-related products, and widened ecodesign to almost every physical product placed on the EU market. The same regulation created the Digital Product Passport (DPP), a framework for green public procurement rules, and a regime against the destruction of unsold consumer products.¹

On its own the ESPR asks nothing specific of a chair, a table or a beech component. It sets the procedure. The Commission writes the actual requirements in delegated acts, one per product group or one per horizontal topic. Each act can set performance requirements, such as a minimum durability or a maximum content of a substance, and information requirements, such as a repairability score or a carbon footprint. Every product-specific act must at least include passport requirements and rules on tracking substances of concern.¹

Annex I of the regulation lists the parameters an act may use: durability and reliability, ease of repair and maintenance, upgrading and reuse, design for recycling, substances of concern, use of energy and resources (including the impact on deforestation), recycled and renewable content, weight and packaging, environmental and carbon footprint, waste, and more.¹ Which of these will apply to furniture is exactly what the current preparatory study is working out.

This article describes the legal texts and Commission documents as of October 2026. It is a practical summary for furniture makers and their suppliers, not legal advice.

Where furniture sits in the ESPR working plan

The Commission adopted the first ESPR working plan on 16 April 2025, for the period 2025–2030. The regulation itself had named furniture, including mattresses, as a priority group. The plan confirmed it: furniture ranked second among the four new final products, behind textiles and ahead of tyres and mattresses, with an EU market size of EUR 140 billion in 2021.³

The plan justifies furniture by its "high potential to improve aspects of resource use". In furniture, the production and supply of materials is often the largest contributor across impact categories such as climate change, acidification and eutrophication.³ The Commission's DPP page repeats the same order in October 2026: iron and steel in the fourth quarter of 2026, textiles, aluminium and tyres in the second half of 2027, furniture in 2028, and mattresses in 2029. It labels all of these dates indicative.²

Two other choices in the plan matter for wood. The first plan does not use the power to extend the ban on destroying unsold products to new product groups.³ And intermediate products are treated with care. For iron, steel and aluminium, the Commission is assessing information-only requirements so that rules on a material do not push manufacturers of final products into difficulty.³ Solid wood components are not an ESPR product group of their own. If they are covered at all, it will be through the furniture act.

From adoption to application: the 18-month rule

Article 4 requires the Commission to give operators sufficient time, particularly SMEs. A delegated act should not apply earlier than 18 months after it enters into force, except in duly justified cases.¹ If the furniture act is adopted in 2028 as planned, the first requirements would therefore apply around 2030 at the earliest. That is our reading of the two dates, not a Commission timetable. The working plan also has a mid-term review in 2028, which could move furniture either way.³

The furniture preparatory study: what is happening now

Every delegated act starts with a preparatory study under the Commission's ecodesign methodology (MEErP), followed by an impact assessment. For furniture, the study is run for DG Environment by a consortium of VITO, Trinomics, Oeko-Institut, Ecoinnovazione and Fraunhofer IZM. The same project also revises the criteria of the EU Ecolabel for furniture.⁴ The contract started on 16 April 2026 and runs for 15 months.⁶

The first stakeholder meeting took place in Brussels on 6 October 2026, with 44 participants in the room and 171 online.⁵ Three draft reports are published for comment: the first four MEErP tasks (scope, market, users, technologies), a mapping of available life-cycle data, and an assessment of possible passport content. Written feedback is due by 10 November 2026 for the first two and by 25 November 2026 for the passport report and for substances of concern.⁴ According to the minutes, a second stakeholder meeting is planned for March 2027, subject to confirmation.⁵

Scope: what counts as furniture

The draft covers both B2B and B2C furniture. Mattresses go through a separate ESPR process. Built-in and bespoke furniture, furniture parts and fittings, upholstered and removable components, and mixed-material furniture were all raised at the meeting as boundary cases that still need work.⁵ German cabinetmakers and craft associations asked for exclusions or simplified rules for bespoke pieces made in very small numbers. Environmental NGOs warned that exclusions could become loopholes.⁵ The study team grouped products into seven functional groups with 44 subgroups to model representative "base cases".⁵

What the evidence shows so far

The market chapter puts EU furniture production at about EUR 76.6 billion in 2024, after a peak of EUR 82.9 billion in 2022. The sector has around 125,000 manufacturers, about 92% of them micro-enterprises, and wood is the dominant material by production value.⁹ Working average lifetimes range from about 10 years for upholstered seating to 15 years for several wooden and metal furniture categories.⁹

The life-cycle mapping confirms the main finding of an earlier literature review by Cordella and Hidalgo (2016): most of the impact sits in the materials.¹⁰

The use phase of furniture is estimated at less than 1% of life-cycle impacts, because furniture uses almost no energy or water in service.⁹ What matters during use is how long a piece stays in service, because a longer life spreads the production impact over more years. That is why durability, repair and spare parts come up in every ESPR discussion about furniture.

The draft groups the relevant circularity aspects into four clusters: durability and reliability; repairability and maintenance; recyclability, recovery of materials and recycled content; and upgradeability, modularity and design for disassembly.⁹ CEN's furniture committee (CEN/TC 207) is preparing circularity standards for all four, but only one is published so far: EN 17902:2023, an evaluation method for the dis- and re-assembly capability of furniture.⁹

How the Digital Product Passport works

The passport is a structured data set about a product, reached through a data carrier such as a QR code that is linked to a persistent unique product identifier. The carrier must be on the product, its packaging or its accompanying documents, as the delegated act specifies. The data must be machine-readable and based on open, interoperable standards, without vendor lock-in.¹

Each delegated act decides the details for its product group: which data, which carrier, whether the passport is kept at model, batch or item level, who may read or update which fields, and how long the passport must remain available. That period is at least the expected lifetime of the product.¹ Customers, repairers, recyclers, market surveillance and customs authorities get free access according to their access rights.¹ The economic operator placing the product on the market must also keep a back-up copy with a passport service provider.¹

The registry and the standards are in place

The regulation required a central registry of unique identifiers by 19 July 2026. Commission Implementing Regulation (EU) 2026/1778 of 16 July 2026 sets the rules for registering, verifying the identity of economic operators and storing data. It also covers passports required by other laws, such as those for batteries, construction products, toys and detergents.¹¹ The Commission reports that the registry went live on 20 July 2026.² Once the registry is linked to the EU customs single window, customs will check the registration identifier of an imported product against the registry before releasing it for free circulation.¹

On the technical side, the Commission cited six harmonised standards drafted by CEN-CENELEC Joint Technical Committee 24 on 15 July 2026: EN 18216 (data exchange protocols), EN 18219 (unique identifiers), EN 18220 (data carriers), EN 18221 (storage, archiving and persistence), EN 18222 (APIs) and EN 18223 (system interoperability).⁷ A passport that follows them is presumed to meet the regulation's technical requirements.⁷ Two more standards, on access rights and security (EN 18239) and on data authentication (EN 18246), were still to be cited; the Commission plans that for November 2026.^2,12

The first group that must actually carry a passport is batteries, from 18 February 2027, under the Batteries Regulation rather than the ESPR.² For furniture there is no date yet.

What a furniture passport might contain

The study's draft passport report starts from what the ESPR always requires and what other EU laws already ask for, then adds fields that stakeholders proposed. Its own label for the result is "derived data fields, to be evaluated" in the next round of consultation.⁶ The selection below shows the fields that matter most to suppliers of wooden parts.

Three points stand out for wood. First, adhesives and coatings appear as a proposed field at component or batch level, and so do wood preservatives and flame retardants where they apply.⁶ Second, a carbon footprint and an environmental footprint (from an LCA, a product carbon footprint or an EPD) are listed, but the methodology is still open.⁶ Our article on EPDs and the carbon footprint of wood products explains what such data look like for hardwood. Third, country of origin and harvest origin for wood appear only as optional fields, with access restricted.⁶

Substances of concern

Article 7(5) is the part of the ESPR that reaches furthest up the supply chain. Unless an act grants an exemption, the information requirements must let substances of concern be tracked throughout the product's life. The passport must give their name, their location in the product, their concentration at product, component or spare-part level, instructions for safe use, and information for disassembly and recycling.¹ "Substance of concern" is defined broadly. It includes substances on the REACH candidate list, substances classified as carcinogenic, mutagenic, toxic for reproduction or sensitising, persistent organic pollutants, and any substance that hampers the reuse or recycling of materials in the product.¹ Candidate-list substances above 0.1% by weight cannot be exempted.¹

For a solid wood part, the wood itself is rarely the issue. The questions are about what is added: adhesives, lacquers, oils, stains, preservatives, and in upholstered seating the foam and fabric treatments. The study team has published a preliminary list of such substances for stakeholders to check.⁵

The ban on destroying unsold products

Since 19 July 2026, large companies may not destroy unsold apparel, clothing accessories and footwear. Medium-sized companies follow on 19 July 2030, and micro and small companies are exempt.¹ Delegated Regulation (EU) 2026/296 sets out the cases in which destruction is still allowed, for example for safety or hygiene reasons, or damage that cannot be repaired at reasonable cost. It applies from the same date.^1,13

Furniture is not on that list, and the first working plan adds nothing to it.³ What does apply to furniture is the separate disclosure duty in Article 24. Economic operators other than micro and small enterprises that discard unsold consumer products must publish, once a year, the number and weight discarded by product category, the reasons, the share sent to reuse, recycling, energy recovery or disposal, and their prevention measures. Medium-sized enterprises are covered from 19 July 2030.¹ Implementing Regulation (EU) 2026/2 sets a standard format from 2 March 2027. Its product list names seats (9401), other furniture and parts (9403) and mattresses and bedding (9404) as separate categories.⁸

What component suppliers will be asked for

The legal duty to provide the passport sits with the economic operator that places the finished product on the market, usually the furniture brand or manufacturer.¹ The data, however, come from everyone upstream. In the words of the draft report, "raw-material and component suppliers hold information on material properties, composition, origin, recycled content, substances and certifications". Furniture manufacturers combine that with specifications, bills of materials and compliance documents.⁶

The same report notes how far the sector is from that today. Some large companies already run integrated product data systems, while many SMEs and craft manufacturers still exchange information as PDFs, spreadsheets and invoices.⁶ For a supplier of hardwood components, the requests that are most likely to come are:

• Material composition per part: species (by botanical name), solid or finger-jointed, weight, and any non-wood material such as dowels, metal inserts or fittings.
• Adhesives and finishes: product names, safety data sheets, and a statement on substances of concern and their concentrations.
• Treatments: whether any preservative, fire retardant or other biocidal product was used.
• Joining and disassembly: how parts are joined, which joints can be undone, and which parts can be supplied as spares.
• Identifiers: part numbers, and batch numbers where the act asks for batch-level data.
• Footprint data: an EPD or product carbon footprint, with the method behind it, once the act fixes a method.

The passport is not an EUDR file. At the stakeholder meeting, the study team clarified that the EU Deforestation Regulation is not part of the passport's scope.⁵ Geolocation, due diligence statements and reference numbers stay in the EUDR system, as our EUDR guide for timber and furniture describes. Clean EUDR records will still help, because species and origin are the same facts in both systems. Certification claims such as FSC or PEFC are a third, voluntary layer, covered in our guide to responsibly sourced timber.

Model, batch or item: why granularity decides the cost

Stakeholders at the meeting raised the question that will most affect cost: at which level the passport is kept. Item-level passports mean one data set per chair or table. Batch-level tracking is what some producers already do. The European furniture confederation EFIC asked for a stepwise, need-to-know approach that looks at who needs each field, who holds it, and what it costs.⁵ For wood, origin can change from one consignment to the next, which is why the draft report expects origin data to need batch or shipment granularity rather than model level.⁶

The timeline at a glance

Anything in the table marked as planned can still move. The working plan has a review in 2028, the Commission's DPP page calls its dates indicative, and the furniture study has not yet reached its policy options.^2,3,5

How we prepare at SARAL

Checklist: how to prepare without over-investing

1. Follow the study, and answer it. Feedback on the draft reports is open until 10 November 2026, and until 25 November 2026 for the passport content and substances of concern. Industry data shape the base cases.⁴
2. Build a clean bill of materials per model. List every part with species, weight, joint type, adhesive, finish and supplier. Most passport fields start there.
3. Collect safety data sheets for every adhesive, finish and treatment, and check them against the REACH candidate list now. Substance tracking is a minimum requirement of every product-specific act.¹
4. Agree part numbers and batch logic with your suppliers. Whether the act chooses model, batch or item level, you will need identifiers that match across companies.
5. Keep EUDR records separate but consistent. Use the same species names and supplier data in both.
6. Ask suppliers what footprint data they have, and on which method. Do not commission a full LCA programme for furniture until the act fixes the method.
7. Do not buy passport software yet for furniture. The data fields, granularity and access rights are still drafts.⁶

For the wider supplier brief, including test reports, tolerances and EUDR data, see our guide to choosing and briefing a hardwood components supplier.

Frequently asked questions

When does the digital product passport become mandatory for furniture?

Not before a furniture delegated act is adopted and applies. As of October 2026, the Commission's indicative date for adopting that act is 2028, and an act normally applies at least 18 months after it enters into force.^1,2,3

Does the ESPR ban the destruction of unsold furniture?

No. The ban covers apparel, clothing accessories and footwear. Companies other than micro and small enterprises that discard unsold furniture must disclose it every year, with a standard format from 2 March 2027.^1,8

What information will a furniture DPP contain?

That is not yet decided. The draft list from the preparatory study includes identifiers, manufacturer details, materials, substances of concern, care and repair instructions, spare parts, recycled content and, with the method still open, a carbon or environmental footprint.⁶

Is the digital product passport the same as EUDR due diligence?

No. The study team stated that the EUDR is not part of the passport's scope. EUDR statements and geolocation stay in the EUDR information system.⁵

Do small furniture makers have to comply with the ESPR?

Once a furniture act applies, its product requirements apply to products whatever the size of the maker, but the regulation requires the Commission to consider SMEs, and the destruction ban and disclosure duty do not apply to micro and small enterprises. Bespoke and small-series furniture is one of the open scope questions in the study.^1,5