Furniture Delegated Act Tracker: ESPR Furniture DPP Status and Timeline

Furniture Delegated Act: Preparatory Study Status

The EU Commission's preparatory study for the ESPR furniture delegated act is currently underway, with a final report expected in 2025. The study is examining the environmental impact of furniture across its lifecycle — from raw material extraction through manufacturing, use, and end of life. Preliminary findings indicate that the most significant environmental impacts of furniture are: embodied carbon from wood and metal processing, chemical substances in surface treatments and adhesives, and end-of-life waste generation (approximately 10 million tonnes of furniture waste per year in the EU). The delegated act is expected to be published in 2026–2027, with a compliance deadline for manufacturers of 2028–2029.

EU Deforestation Regulation and Furniture DPP Interaction

The EU Deforestation Regulation (EUDR, EU 2023/1115) entered into force in June 2023 and applies to cattle, cocoa, coffee, palm oil, soya, wood, and rubber, as well as derived products including furniture containing wood. The EUDR requires operators placing these products on the EU market to conduct due diligence and submit a due diligence statement before placing the product on the market. The ESPR furniture DPP will incorporate the EUDR due diligence data — specifically, the geolocation coordinates of the forest plots from which the wood was harvested and the forest certification references. Furniture manufacturers that are already complying with the EUDR will have a significant head start on the ESPR furniture DPP wood origin data requirements.

Furniture Sector Engagement with ESPR Consultation

The European furniture industry trade association, EFIC (European Furniture Industries Confederation), has been actively engaged in the ESPR furniture delegated act consultation process. EFIC has published position papers on the ESPR preparatory study, highlighting the sector's concerns about the cost of DPP implementation for SMEs (small and medium-sized enterprises), which represent the majority of EU furniture manufacturers. The EU Commission has acknowledged these concerns and is developing simplified DPP implementation pathways for SMEs, including a collective DPP model where industry associations manage the DPP infrastructure on behalf of their members. Furniture manufacturers should engage with EFIC and their national trade associations to stay informed about the delegated act consultation process and to influence the final requirements.

Furniture Sector Preparatory Study: Key Findings

The EU Commission's preparatory study for the ESPR furniture delegated act identified the following key environmental impact areas for furniture: greenhouse gas emissions from material production (particularly steel, aluminium, and foam), formaldehyde emissions from engineered wood products, VOC emissions from surface treatments, and end-of-life waste (furniture is one of the largest waste streams in the EU, with approximately 10 million tonnes of furniture waste generated annually). The preparatory study recommended that the furniture delegated act focus on: minimum recycled content requirements for steel and aluminium components, maximum formaldehyde emission limits for engineered wood products, minimum durability requirements (tested against EN 1725, EN 1728, EN 12520, EN 12521), and repairability requirements (availability of spare parts, disassembly instructions).

Furniture DPP: What Manufacturers Must Prepare Now

Furniture manufacturers should begin their ESPR preparation now, even though the delegated act is not expected until 2027. Key preparation activities include: conducting a material composition audit of their product portfolio to identify the primary materials used and their recycled content; testing their products against the relevant EN durability standards; assessing the repairability of their products (availability of spare parts, ease of disassembly, availability of repair instructions); and engaging with their timber suppliers to obtain Forest Stewardship Council (FSC) or Programme for the Endorsement of Forest Certification (PEFC) certification for their timber components. Manufacturers that complete these preparation activities before the delegated act is published will be able to implement compliance much faster and at lower cost.

EU Timber Regulation and ESPR Furniture

The EU Timber Regulation (EUTR, EU 995/2010) prohibits the placing on the EU market of illegally harvested timber and timber products. The EUTR requires operators placing timber products on the EU market to exercise due diligence — assessing the risk that the timber was illegally harvested and taking steps to mitigate that risk. The ESPR furniture DPP will require disclosure of the timber origin and certification status for furniture containing wood components. Furniture manufacturers that are already complying with the EUTR (by implementing a due diligence system and obtaining FSC or PEFC certification for their timber suppliers) will have a foundation for the ESPR DPP timber origin disclosure requirements.

Furniture Sector ESPR Timeline: Key Milestones

The furniture sector ESPR timeline has three key milestones that manufacturers should plan around. The first milestone is the publication of the preparatory study by the EU Commission's Joint Research Centre (JRC), expected in 2025–2026. The preparatory study will define the scope of the furniture delegated act, identify the key ecodesign parameters, and propose minimum performance requirements. Furniture manufacturers should participate in the preparatory study consultation — the JRC publishes draft preparatory study reports for public comment, and manufacturers that submit well-evidenced comments can influence the final requirements. The second milestone is the publication of the draft delegated act, expected in 2026–2027. The draft delegated act will specify the exact requirements — manufacturers should review the draft carefully and submit comments on any requirements that are technically infeasible or disproportionately burdensome. The third milestone is the compliance deadline, expected in 2029. Manufacturers should plan their compliance implementation to be complete at least 6 months before the compliance deadline, to allow time for any last-minute issues to be resolved.

Furniture manufacturers that export to markets outside the EU should also monitor the development of similar regulations in other jurisdictions. The UK has committed to implementing a similar ecodesign and DPP framework under the Product Security and Telecommunications Infrastructure Act, and several other countries (Canada, Australia, Japan) are developing similar regulatory frameworks. Manufacturers that implement ESPR DPP compliance will be well-positioned to comply with these other frameworks, as the core data requirements are similar. The investment in ESPR DPP compliance is therefore not just a cost of EU market access — it is an investment in a global compliance infrastructure that will provide returns across multiple markets.

Small and medium-sized furniture manufacturers (fewer than 250 employees) may be eligible for simplified ESPR compliance procedures under the SME Relief Package that the EU Commission is developing. The SME Relief Package is expected to provide simplified DPP data requirements, extended transition periods, and financial support for SME compliance implementation. Furniture manufacturers that qualify as SMEs should monitor the development of the SME Relief Package and engage with their national SME support agency (such as the Enterprise Europe Network) to access the available support. However, SMEs should not use the SME Relief Package as a reason to delay their ESPR compliance preparations — the simplified procedures will reduce the compliance burden but will not eliminate it, and SMEs that begin their compliance preparations early will be better positioned to meet the compliance deadline.