Published 9 June 2026 · 8 min read · by Nora Corrado, DPP Readiness Agency HCMC
The EU Ecodesign for Sustainable Products Regulation — Regulation (EU) 2024/1781, entered into force on 18 July 2024 — is a framework regulation. This is a critical distinction: it does not itself specify what data your furniture needs to carry, or by when. Instead, it establishes the legal framework, the governance structure, and the mechanism through which specific requirements will be determined.
Think of it as the constitution of a new compliance regime. The specific laws — for your specific product category, with your specific data requirements and your specific enforcement date — come in subsequent layers.
Establishes the legal framework, Digital Product Passport concept, mandatory data fields (Annex III), governance through ESPR Committee, DPP Registry infrastructure, and the mechanism for sector-specific delegated acts.
The European Commission issues a Delegated Act for each product group. For furniture, this is expected in 2027. The Delegated Act specifies: exactly which data fields are mandatory for furniture, the measurement methodologies for LCA and carbon footprint, the minimum recyclability requirements, and the enforcement date (expected 2028-2029 for furniture).
Implementing Acts specify the technical standards for data exchange: the GS1 Digital Link Standard v1.3 for QR code structure, ISO/IEC 18004:2015 for QR code carriers, GS1 EPCIS 2.0 for data exchange, and the specific format requirements for DPP Registry submission.
ESPR does not treat all product data equally. It establishes a hierarchy of verification rigor, each level with different legal standing:
Manufacturer declares data. Valid only for durability and end-of-life claims. No independent verification.
Required for all Annex III mandatory fields. Third-party verification against ESPR standard. FSC, REACH compliance, EN 15804+A2 qualify.
Highest level. EPD certified per EN 15804+A2, ISO 14044:2006 LCA, lab-accredited testing. Required for carbon footprint claims.
The DPP is accessed through a QR code on the physical product. That QR code is not just a URL — it is a structured identifier following the GS1 Digital Link Standard v1.3 (2024), which encodes the product's Global Trade Item Number (GTIN), batch/lot number, and serial number in a standardized URL format.
This means that before worrying about what data goes in your DPP, you need a product serialization and digital identification system that is GS1-compatible. For manufacturers currently operating with internal item codes and manual tracking systems, this is a significant infrastructure investment.
The three-layer architecture creates a preparation paradox: the specific requirements for furniture won't be fully defined until the 2027 Delegated Act, but by the time that Act is published, manufacturers who haven't started will have 18 months or less to achieve compliance. The structural work — supply chain mapping, data collection, system integration — takes 18-24 months.
The companies that will be DPP-ready in 2028 are the ones that begin preparation in 2026, working from the Framework Regulation's Annex III fields and the expected requirements of the furniture Delegated Act — even before they are formally enacted.
Sources: Regulation (EU) 2024/1781 (ESPR), Official Journal of the EU, 18 July 2024 · GS1 Digital Link Standard v1.3 (2024) · ISO 14044:2006 · EN 15804:2012+A2:2019 · NDI DPP Readiness Assessment Framework v1.2
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