---
title: "We sell furniture and no specific EU act covers it"
description: "Where no specific Union act regulates its safety, consumer furniture falls under the General Product Safety Regulation (EU) 2023/988. It must be safe. Conformity with European standards published in the Official Journal gives a presumption of safety for the risks they cover. Before placing it on the market, carry out a risk analysis, draw up technical documentation and supply clear assembly instructions and warnings."
type: "problem"
url: "https://www.conphora.com/solutions/problem/furniture-general-safety/"
markdown: "https://www.conphora.com/solutions/problem/furniture-general-safety.md"
locale: "en"
language: "en"
updated: "2026-10-05"
author: "Conphora compliance team"
publisher: "Conphora"
source: "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R0988-20260529"
tags: ["GPSR", "REACH", "placing-on-market"]
license: "Free to quote with attribution and a link to the page"
---

# We sell furniture and no specific EU act covers it

Where no specific Union act regulates its safety, consumer furniture falls under the General Product Safety Regulation (EU) 2023/988. It must be safe. Conformity with European standards published in the Official Journal gives a presumption of safety for the risks they cover. Before placing it on the market, carry out a risk analysis, draw up technical documentation and supply clear assembly instructions and warnings.

## Why this happens

Most furniture has no product act of its own, so the General Product Safety Regulation (EU) 2023/988 does the work. It applies to products placed or made available on the market insofar as no specific provisions with the same objective under Union law regulate their safety; where specific requirements exist, it covers only the risks they leave open, and for products subject to Union harmonisation legislation its Chapter III, Section 1 (Articles 9 to 18) does not apply (Article 2(1)). It applies to new, used, repaired and reconditioned products alike (Article 2(3)). The core duty is short: economic operators place or make available only safe products (Article 5). [1] The Commission's guidelines name furniture and childcare articles as products the GPSR applies to fully (Commission Notice C/2025/6233, section 2.2). [3]

Safety is assessed against named aspects. Article 6(1) lists the product's characteristics, including its design, composition, packaging and instructions for assembly, installation, use and maintenance; its effect on other products used with it; its presentation, labelling and warnings; the categories of consumers, in particular vulnerable consumers such as children, older people and persons with disabilities; and appearance that may lead to use other than intended, including products not designed for children that are likely to be used by them. The feasibility of a higher safety level is not in itself a reason to call a product dangerous (Article 6(2)). [1]

Standards decide how much proof is enough. A product is presumed to meet the general safety requirement where it conforms to European standards whose references are published in the Official Journal under Regulation (EU) No 1025/2012, for the risks they cover; without such standards, conformity with the national health and safety requirements of the Member State of sale gives the presumption (Article 7(1)). The presumption does not stop authorities acting on evidence that the product is dangerous (Article 7(3)). Where no presumption applies, the assessment takes into account other European standards, international standards, voluntary certification schemes, Commission guidelines, national standards, the state of the art, codes of good practice and reasonable consumer expectations (Article 8(1)). [1]

The manufacturer documents the result before placing the product on the market. Article 9(2) requires an internal risk analysis and technical documentation with at least a general description of the product and its essential safety characteristics, and, where appropriate, the analysis of risks and the solutions adopted, the outcome of test reports and the list of standards or other elements applied. The documentation is kept up to date and kept for 10 years (Article 9(3)). The product carries a type, batch or serial number and the manufacturer's name and postal and electronic address, and comes with clear instructions and safety information (Article 9(5) to (7)). An importer checks that the manufacturer has done this before placing the product on the market (Article 11(1)). [1]

Chemical restrictions apply alongside. After 6 August 2026, furniture and wood-based articles may not be placed on the market if, under the test conditions in Appendix 14, the concentration of formaldehyde they release exceeds 0.062 mg/m³; for other articles the limit is 0.080 mg/m³ (REACH, Regulation (EC) No 1907/2006, Annex XVII, entry 77, point 1). Articles exclusively for outdoor use and second-hand articles are among the exceptions. The restriction applies alongside the GPSR and does not replace the risk analysis and technical documentation under Articles 9 and 11; keep the formaldehyde test report or the supplier's evidence in the file. [4]

Online sales add their own information duties. An offer must show the manufacturer's name and addresses, the responsible person where the manufacturer is outside the Union, a picture and identifiers of the product, and its warnings and safety information in the language the Member State determines (GPSR Article 19). [1]

A manufacturer outside the Union also needs a partner inside it. The product may not be placed on the market unless an economic operator established in the Union is responsible for the tasks in Article 4(3) of Regulation (EU) 2019/1020 (GPSR Article 16(1)): keeping the documentation available, answering an authority's reasoned request in a language it understands, informing it of risks and cooperating on corrective action (Regulation (EU) 2019/1020 Article 4(3)). [2]

## How to solve it

1. **Confirm which rules cover the piece** Check whether any specific Union act regulates the safety of the item, for example because it has a motor, lighting or a radio module. Risks such an act covers are handled under it, and the GPSR's general safety requirement covers the risks it leaves open; the GPSR's own duties for manufacturers and importers in Articles 9 to 18 then do not apply. Furniture with no specific act at all falls fully under the GPSR.
2. **Find the standards that give a presumption of safety** Look first for European standards whose references are published in the Official Journal under Regulation (EU) No 1025/2012. Where none exists, national health and safety requirements of the Member State of sale give the presumption. If neither applies, use the elements in Article 8: other European standards, international standards, Commission guidelines, the state of the art and reasonable consumer expectations.
3. **Assess the design against the GPSR aspects** Cover the design, technical features and composition, the instructions for assembly, installation and maintenance, the effect of other products used with it, the warnings, and the people who will use it, including children and older people. Include foreseeable use by children even where the piece is not intended for them.
4. **Record the solutions and the tests** Write the internal risk analysis into the technical documentation: the risks found, the solutions adopted, the outcome of any test reports and the list of standards or other elements applied. Where a standard was only partly applied, identify the parts that were.
5. **Identify the product and write the instructions** Give each model a type, batch or serial number visible to consumers, put the manufacturer's name and postal and electronic address on the product or packaging, and supply clear assembly instructions and safety information in the language of each country of sale. Online listings show the same identifiers and warnings.

## What you need to show

- **The internal risk analysis and technical documentation, with the standards applied** — The manufacturer (GPSR Article 9(2))
- **Test reports used as evidence in the risk analysis** — The manufacturer or a laboratory acting for it (GPSR Article 9(2)(a))
- **Assembly instructions and safety information in the languages of the countries of sale** — The manufacturer; the importer checks them (GPSR Articles 9(7) and 11(4))

## If you do nothing

- **Only safe products may be sold** — Economic operators may place or make available on the market only safe products (GPSR Article 5). An importer that has reason to believe a product does not conform may not place it on the market until it does (Article 11(2)).
- **The presumption of safety is not a shield** — Even where a product conforms to the European standards or national requirements that give a presumption of safety, market surveillance authorities may take all appropriate measures where there is evidence that the product is dangerous (GPSR Article 7(3)).
- **Corrective action when a risk appears** — A manufacturer that considers or has reason to believe a product it placed on the market is dangerous must immediately take corrective measures, including withdrawal or recall where appropriate, inform consumers and notify the authorities through the Safety Business Gateway (GPSR Article 9(8)).

## Questions

### Does furniture need a CE marking?

Not because it is furniture. The duties for a product covered only by the General Product Safety Regulation are a safe product, an internal risk analysis, technical documentation, identification and instructions (Articles 5 and 9). Parts covered by a specific Union act follow that act.

### Which standards should we test against?

European standards whose references are published in the Official Journal give a presumption of conformity for the risks they cover (GPSR Article 7(1)(a)). Without one, use national requirements of the country of sale (Article 7(1)(b)) and the elements listed in Article 8(1), such as international standards and the state of the art.

### Our furniture is for adults. Do we have to think about children?

Yes. The safety assessment considers vulnerable consumers such as children and older people (GPSR Article 6(1)(e)), and products that, though not intended for children, are likely to be used by them (Article 6(1)(f)(ii)).

### Do assembly instructions count as part of safety?

They do. Instructions for assembly, installation, use and maintenance are part of the product characteristics assessed under GPSR Article 6(1)(a), and the product must come with clear instructions and safety information in a language consumers easily understand (Article 9(7)).

### We sold this model before December 2024. Does that change anything?

Member States may not impede the making available of products that conform to Directive 2001/95/EC and were placed on the market before 13 December 2024 (GPSR Article 51). Units placed on the market from that date fall under the regulation, which applies from 13 December 2024 (Article 52); placing on the market is the first making available of each product (Article 3(7)).

## Regulations involved

GPSR, REACH

## Sources

1. [Regulation (EU) 2023/988 on general product safety (consolidated text of 29 May 2026)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R0988-20260529) — EUR-Lex, 2026-10-04
2. [Regulation (EU) 2019/1020 on market surveillance and compliance of products (consolidated text of 12 August 2026)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02019R1020-20260812) — EUR-Lex, 2026-10-04
3. [Commission Notice — Guidelines on the application of the EU general product safety legislative framework by businesses (C/2025/6233)](https://eur-lex.europa.eu/eli/C/2025/6233/oj) — EUR-Lex, 2026-10-05
4. [Regulation (EC) No 1907/2006 (REACH), Annex XVII (consolidated text of 22 June 2026)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02006R1907-20260622) — EUR-Lex, 2026-10-05