do I need to include information about dust mites or allergens in the passport
Not yet established as mandatory data
At present, there is no requirement anywhere stating that allergy information such as dust mite resistance or allergens must be included in the digital product passport for a mattress. The ESPR itself (Regulation (EU) 2024/1781) lists in Articles 5 to 7 a series of categories on which requirements can be set — think of sustainability, reusability, presence of substances of concern and environmental impacts — but which specific data must concretely appear in the passport for mattresses will only be determined in a product-specific implementing measure. That measure for mattresses does not yet exist. Allergy information is not a component that is already mentioned as a mandatory element in the current ESPR text itself.
For whom this is relevant, and for whom it is not
This question is particularly relevant for manufacturers who currently make voluntary claims about dust mite-resistant material, antibacterial finishes or hypoallergenic filling — often on packaging or in marketing materials. For them, the question is whether such a claim will become a mandatory passport field, or whether it remains a voluntary addition alongside mandatory data. For manufacturers who do not make allergy-related claims, the question is less urgent: without a claim, there is no reason to substantiate that information anywhere. It is also important to distinguish between other components of the passport that are already more concretely described, such as material composition or flame retardants — these fall under quite different assessment frameworks than an allergen claim, and are not treated interchangeably.
The date is not fixed, just like the rest of the content
No date is known on which an obligation to provide allergy information would take effect, simply because that obligation does not yet exist and is not circulating as a proposal within the known planning. What is established: the delegated act that will concretely determine the content of the mattress passport is expected in 2028 according to the ESPR work plan 2025-2030. Until that act is published, there is no legal basis for determining whether, and if so how, allergy information will have a place. This page will be updated once that text is available.
What to do until the mandatory content is established
Anyone currently placing a mattress on the market with a claim about dust mites or allergens is well advised to continue substantiating that claim as is already required — with test results or certification that supports the claim. This is independent of the product passport and does not change with its introduction. When the implementing measure is in place, it makes sense to consider whether allergy-related properties fall under one of the broader categories already mentioned, such as substances that are important for health during use. Until then, it is practical to get the dossiers that are already mandatory in order — material composition, flame retardants, origin of raw materials — so that there is a structure into which any new data can later be incorporated. A good overview of what is already known there can be found in what data will be included in the product passport for mattresses. Anyone in doubt about whether an allergen claim or composition of filling material can be considered commercially sensitive and thus does not have to be made public can find background in whether business-sensitive data about mattresses must be made public. It is also useful to think about who will have access to this kind of sensitive product information, because not all data in the passport is visible to everyone — see which data from the product passport each party may view.
The legal basis: Articles 5-7 and Article 10 of the ESPR
The ESPR (Regulation (EU) 2024/1781) operates with a layered structure. Articles 5 to 7 describe the broad categories on which ecodesign requirements and information requirements can be based — performance requirements and information requirements that are further detailed per product group. Article 10 then describes what the digital product passport must generally be able to contain and how that passport must function technically and organisationally. Neither of these articles mentions allergy information, dust mites or comparable health claims as a specific data point. That specification only comes with the delegated act that is adopted per product group — in this case mattresses — and which does not yet exist. Until that time, any statement about an obligation to include allergy information in the passport cannot be substantiated from the text currently available.
For those already working with claims about dust mites or allergens, it is best to keep that substantiation in order as usual, to follow the development of the mattress-specific implementing measure, and to set up first the mandatory passport data that are already known — such as foam type, flame retardants and disposal instructions — so that there is space and structure to add any new obligations without difficulty.
Where this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 10 (requirements for the digital product passport)
- Regulation (EU) 2024/1781 (ESPR), Articles 5 to 7 (requirements regarding ecodesign, performance and information requirements)
The regulation itself is on EUR-Lex. We provide references per statement; you do not have to take our word for it.
What you concretely must do
What is expected of you
The ESPR determines in Articles 5 to 7 that the delegated act lays down for each product group which information and performance requirements apply. For mattresses, that delegated act does not yet exist, and consequently it has not yet been determined whether allergy information — such as anything about dust mites, substances used that are known to be allergenic, or the extent to which a cover is washable with regard to allergens — must be included as mandatory in the passport. What follows here is therefore a description of how such information is normally treated within the ESPR system, not a statement about what will apply for mattresses.
Information that is linked to a performance requirement
Article 10 of the ESPR links the content of the product passport to the requirements established for the product group. In practical terms, this means that allergy information will only find a place in the passport once the delegated act for mattresses attaches a concrete requirement to it — for example a limit value for a substance, a test method, or a mandatory statement about a particular material. Without such a requirement, there is also no passport field. A company with 10 to 100 employees therefore does not need to guess now at a format; it is more useful to follow which substances and materials will be mentioned, and to establish that link with what is already known about what data will be included in the product passport for mattresses.
Distinction from existing substance rules
Allergy-related information often runs together with rules that already exist, separate from the ESPR — think of statements about certain chemical substances on a label, or what a cover manufacturer already indicates about composition. For a company, this means the question "must this be in the passport" is actually two questions: is it already required to be stated somewhere (then the question is whether the passport incorporates that), and is there a new, specific requirement coming via the mattress regulation. These two tracks can ultimately converge, but for now they are still separate.
Distinction between mandatory and voluntary disclosure
Even if there is no legal obligation to state anything about dust mites or allergens, it remains possible to do so voluntarily — as manufacturers already make claims about "hypoallergenic" material or washable covers. For a company, this means a choice: including voluntary information in the passport can be a sales argument, but any statement that is included must also be substantiable. This touches on the question of how such a property has been established, which connects to the way other characteristics are also measured and substantiated, as described in the method by which values for the passport are measured.
Connection with other material information already expected
Apart from a separate allergen declaration, there are parts of the product passport that are firmly anchored in the broader ESPR system and that can indirectly relate to allergens — such as information on foam type and composition. Anyone who establishes this now how foam type and density are recorded in the product passportbuilds a foundation that will be easier to expand later, should an allergen-related requirement come into effect.
Where things go wrong in practice
A first situation: a manufacturer claims "anti-allergenic" on the packaging and adopts that term literally in the product passport, without an underlying test or standard to support it. As long as there is no legal requirement that defines the term, it is a claim that stands on its own and must be substantiated separately — the product passport gives the claim no additional status.
A second situation: a bed specialist retailer asks the manufacturer to add "something about dust mites" because a customer requests it, and the manufacturer adds a line of text without a source. If a question about it arises later, there is nothing to fall back on.
A third situation: an importer assumes that allergy information "is already mandatory somewhere in the textile" and automatically transfers this to the passport. Textile regulations and ESPR requirements for mattresses are two separate tracks — this difference will be worked out in the question of whether in addition to the digital product passport, a separate textile label must still be kept.
A fourth situation: a manufacturer waits with all material documentation until the delegated act is in place, and then has to quickly find out which substances are in which mattresses. This work is easier to do while production is still running than afterwards.
A fifth situation: a hotel purchaser requests in a tender "allergy-free mattresses with passport", a claim that the passport cannot currently substantiate because there is no established definition or test method for it.
What you can record
- An overview of materials and substances used in the mattress and the cover, including origin, even if there is currently no mandatory disclosure requirement for these.
- Test reports or certificates supporting claims already being made, such as "hypoallergenic" or "washable at high temperature".
- Documentation on the composition of the foam and any coatings, in line with what is already being recorded for other parts of the product passport.
- A file containing the source of each voluntary claim, so that when a customer or competent authority asks, it is clear what the claim is based on.
- A checklist of the ESPR work programme for mattresses, so that it is visible when the delegated act appears and what requirements it contains.
- A note on the distinction between mandatory information and marketing claims, so that both are not accidentally merged in the passport text — something that is also relevant when recording the separation instruction of a mattress, where material separation and origin must likewise be described with precision.
This is not legal advice. This page provides general information about the legislation this platform concerns. We do not know your situation. If you are in doubt about your own case, consult a lawyer or the competent supervisory authority.
Written with AI based on the sources above, reviewed by a human on 2026-09-05. Is something not correct? Let us know — corrections are given priority.