EU Ecodesign Regulation 2024/1781: What the Text Says About Digital Product Passports, Importers and Priority Product Groups Such as Furniture, Steel and Aluminium

Regulation (EU) 2024/1781, the Ecodesign for Sustainable Products Regulation, was adopted on 13 June 2024 and published in the Official Journal on 28 June 2024. Article 80 states that it enters into force on the twentieth day after publication. It replaces Directive 2009/125/EC and sets a framework: it does not itself fix technical requirements for furniture, steel or building products. Those requirements are to arrive product group by product group, through delegated acts.

This article reads the Regulation as published (Official Journal text), read on 12 October 2026. It covers the articles that matter to a buyer importing from China into the EU: scope, how requirements are set, the digital product passport, the priority product groups and the duties of manufacturers and importers once a product group is covered. It is a reading of the legal text for procurement planning, not legal advice. We did not read the Commission’s working plan or any delegated act adopted under it, so check the Commission’s published documents for which groups are covered and from when. For related EU topics, see our guides to the General Product Safety Regulation and CBAM for aluminium and steel.

Scope and what the Regulation actually fixes

Article 1(1) says the Regulation establishes a framework for the setting of ecodesign requirements that products have to comply with to be placed on the market or put into service, with the aim of improving environmental sustainability. It also establishes a digital product passport, provides for mandatory green public procurement requirements and creates a framework to prevent unsold consumer products from being destroyed.

Article 1(2) applies the Regulation to “any physical goods that are placed on the market or put into service, including components and intermediate products”, and lists what it does not apply to, including food, feed, medicinal products, living plants and animals, and certain vehicles in respect of aspects covered by sector rules.

The practical point is in Article 4. The ecodesign requirements are set by delegated acts of the Commission, and the Regulation itself says (Article 4(4)) that 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. Article 4(7) says the first delegated act shall not enter into force before 19 July 2025. Until a delegated act covers a product group, the Articles on manufacturers and importers that refer to “products covered by a delegated act” do not bite on it.

What a delegated act can require

Article 5(1) lists the product aspects that the ecodesign requirements in delegated acts shall improve, where relevant to the product group. They include durability, reliability, reusability, upgradability, repairability, the possibility of maintenance and refurbishment, the presence of substances of concern, energy use, water use, resource use, recycled content, the possibility of remanufacturing and recyclability. Delegated acts may set performance requirements and information requirements for these aspects (Articles 5 to 7).

Article 4(6) lets a delegated act add further requirements where appropriate for a product group, including a different retention period for technical documentation, a duty to make part of the technical documentation digitally available, and reporting of quantities placed on the market. For a buyer, this means the content of the file depends on the delegated act for the specific product, and not on the Regulation alone.

The digital product passport

Article 9(1) provides that the information requirements shall state that products can only be placed on the market or put into service if a digital product passport is available in accordance with the applicable delegated acts and with Articles 10 and 11. The data in the passport shall be accurate, complete and up to date.

• What the delegated act specifies (Article 9(2)): the data to include, the data carrier, its layout and position, whether the passport is at model, batch or item level, who may access which data, who creates or updates it, and the period it remains available, which shall correspond to at least the expected lifetime of the product.
• Why (Article 9(3)): so that actors in the value chain can access product information, so that national authorities can verify compliance and so that products can be traced.
• Possible exemption (Article 9(4)): the Commission may exempt product groups where technical specifications are not available or where other Union law already provides a system for the digital provision of information that achieves the same objectives.

Articles 10 to 14 deal with the requirements for the passport, unique identifiers, the registry and the web portal. Article 15 deals with customs controls relating to the digital product passport. We did not read Articles 10 to 15 in detail for this article, so treat the list above as the starting point and read those Articles with your adviser if a delegated act covers your product.

Priority product groups named in the Regulation

Article 18(3) requires the Commission to adopt a working plan listing the product groups to be prioritised and the estimated timelines. Article 18(5) states that, in the first working plan, which shall be adopted by 19 April 2025, the Commission shall prioritise the following product groups:

• iron and steel;
• aluminium;
• textiles, in particular garments and footwear;
• furniture, including mattresses;
• tyres;
• detergents;
• paints;
• lubricants;
• chemicals;
• energy-related products for which ecodesign requirements are to be set for the first time or reviewed;
• information and communication technology products and other electronics.

The Regulation adds that if any of these groups is not included in the first working plan, or if any other product group is included, the Commission shall justify its decision in the plan. Article 18(6) separately addresses cement: where adequate requirements are absent under the construction products Regulation, the Commission shall set ecodesign requirements for cement in a delegated act not earlier than 31 December 2028 and not later than 1 January 2030. We did not read the working plan itself, so this article does not say which groups the Commission finally listed or when.

What manufacturers and importers must do once a delegated act applies

Articles 27 and 29 apply to products covered by a delegated act. The points below are quoted or closely paraphrased from the text.

• Manufacturer, Article 27(1)–(2): products designed and manufactured in accordance with the performance requirements, accompanied by the required information, with a digital product passport available; the conformity assessment procedure carried out; technical documentation drawn up; where compliance is shown, an EU declaration of conformity and CE marking, or the alternative marking a delegated act specifies.
• Retention, Article 27(3): technical documentation and the EU declaration of conformity kept for 10 years after the product is placed on the market, unless the delegated act specifies a different period.
• Identification, Article 27(5)–(6): a type, batch or serial number or other identifying element, and the manufacturer’s name, trade name or trade mark and postal and electronic contact details on the product, packaging or accompanying document, and on the public part of the passport where applicable.
• Digital instructions, Article 27(7): instructions in digital format in a language that can be easily understood, as determined by the Member State, and safety information in paper format in a concise form.
• Importer, Article 29(1)–(3): place on the market only products that comply; before doing so, ensure the manufacturer has carried out the conformity assessment and drawn up the technical documentation, that the product is accompanied by the required information, that a digital product passport is available, and that the CE marking is borne where applicable; indicate the importer’s own name and contact details.
• Importer’s file, Article 29(7): keep a copy of the EU declaration of conformity and be able to make the technical documentation available for 10 years, unless the delegated act specifies otherwise.
• On request, Articles 27(10) and 29(8): provide the information and documentation to a national authority in an easily understood language, in any event within 15 days of receipt of a reasoned request.

Green public procurement and unsold consumer products

Article 65 provides that contracting authorities shall award public contracts complying with minimum requirements for products covered by delegated acts, or for works and services where those products are used, with the minimum requirements to be set by implementing acts of the Commission. For a supplier to public projects in the EU this means the requirements for a product group may later appear in tender documents.

Articles 23 to 25 concern unsold consumer products. Article 25(1) states that from 19 July 2026 the destruction of unsold consumer products listed in Annex VII shall be prohibited, with micro and small enterprises excluded and medium-sized enterprises covered from 19 July 2030. We did not read Annex VII, so we do not say which products it lists. These Articles concern consumer products in the hands of economic operators that hold unsold stock, and are not a requirement placed on a factory in China.

What to put in a China purchase brief

The Regulation places duties on the parties named in it, and only for products covered by a delegated act. The following are questions a buyer can write into the brief so the file exists before goods ship. Put each answer in writing and keep it with the purchase order.

• Is the product group covered by a delegated act at the shipment date? Ask your adviser to check the Commission’s working plan and the list of adopted delegated acts.
• Who is the manufacturer and who is the importer in the sense of Articles 27 and 29? Name each, and where the destination is the EU name the party that will hold the file.
• Data the factory can supply: materials, recycled content, substances of concern and repair or spare-part information for the exact model, in writing.
• Identification: which type, batch or serial number will be on each product or on its packaging.
• Change notice: whether the factory will tell the buyer before changing a material, a component or a source.
• Record keeping: who keeps the technical documentation for 10 years and where.

See our guides to the EU formaldehyde limit for furniture and the EU deforestation regulation for wooden furniture for two EU rules that already apply to furniture.

Questions buyers ask about the EU Ecodesign Regulation

Does the Regulation already set requirements for furniture?

Not by itself. Article 18(5) names furniture, including mattresses, among the product groups to be prioritised in the first working plan, but requirements for a product group arrive through delegated acts under Article 4. Check the Commission’s published delegated acts for the current position.

When do delegated act requirements start to apply?

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 for the whole act or for specific requirements. Each delegated act states its own dates.

What is the digital product passport?

Article 9 makes availability of a digital product passport a condition of placing a covered product on the market, with data that is accurate, complete and up to date. The delegated act for each product group sets what data the passport contains and how it is accessed.

Who has to hold the technical documentation?

Under Articles 27(3) and 29(7), the manufacturer keeps the technical documentation and the EU declaration of conformity for 10 years, and the importer keeps a copy of the declaration and must be able to make the documentation available for the same period, unless a delegated act specifies otherwise.

Does the Regulation apply to goods before a delegated act covers them?

The duties of manufacturers and importers in Articles 27 and 29 are written for products covered by a delegated act. Whether your product is covered at a given date is a question for your adviser to check against the delegated acts in force.

How does FBM Sourcing support this kind of project?

We review the brief, collect comparable quotations and manage the package for the project. For suppliers you nominate, we charge a 5% commission; for products we source for you, we quote a direct price. Our own team performs one inspection after bulk production is complete and before shipment, and the client’s project team is welcome to attend.

FBM Sourcing manages the entire China procurement package for overseas construction projects. We work with Developers · General Contractors · Builders · Commercial Project Owners · Interior Design & Construction Companies · FF&E Solution Providers.