What obligations does a distributor or trader of mattresses have?
Distributors check, they do not create the passport themselves
For a distributor or trader of mattresses, it is required that they check whether the digital product passport and the associated QR code are present before offering the mattress, and that they do not sell the product if these are missing or clearly incomplete. This is the core of Article 30 of the ESPR (Regulation (EU) 2024/1781): the distributor or trader does not need to compile the passport themselves — the manufacturer or importer does that — but they are the last link that checks whether it is there before the product reaches the customer. Furthermore, the QR code must remain intact and readable during storage, transport and presentation in the shop, and cooperation must be provided if a supervisory authority requests information. Anyone who suspects that a mattress does not meet the requirements should report this to the manufacturer or importer instead of simply selling it.
For wholesale and retail, not for the manufacturer and not for the end user
These obligations apply to any party that places a mattress on the market without being a manufacturer or importer themselves: wholesalers, bed specialist shops, webshops and purchasing organisations that resell mattresses to hotels or other businesses. A hotel that purchases mattresses for its own use is an end user and thus does not fall under this — that party does not need to check anything in the distributor role. The manufacturer and importer do not fall under this either: different, more stringent obligations apply to them (compiling the passport, technical documentation), which are set out elsewhere in the ESPR.
An important exception is contained in Article 31: anyone who places a mattress on the market under their own brand name, or modifies the product in a way that could affect compliance with the requirements, is treated not as a distributor but as a manufacturer for that product. This is relevant for bed specialist shops that have mattresses produced under their own label — that group then receives the full manufacturer obligations, not the lighter distributor role described above.
No fixed entry date yet, but a confirmed work plan
There is no established date yet on which these obligations for mattresses will concretely come into force. The ESPR itself is the framework regulation; the requirements for mattresses specifically come in a delegated act, and according to the ESPR work plan 2025-2030, this is expected around 2028. Until that act is published, no product passport obligations based on the ESPR apply to mattresses — Articles 30 and 31 do describe how the division of roles will work in future, but the date on which this will concretely apply to mattresses is not yet fixed. Once the delegated act is in place, that date will be stated here.
How a trader or distributor can tackle this in practice
Anyone purchasing and reselling mattresses as a wholesaler or retailer can approach this in the following order. First: ask the manufacturer or importer whether and when the digital product passport and QR code will be supplied with the product, and record this in the purchasing agreements. Next: on receipt and storage, check that the QR code on the packaging or product remains visible and scannable — do not cover it over when repacking, do not remove it when changing covers or labels without providing an alternative. Then: if in doubt about the accuracy or completeness of the passport, ask the supplier about this before the product is resold, rather than assessing it yourself or ignoring it. Also helpful: keep a simple internal overview of which suppliers already provide a passport and which do not yet, so that this is clear if a supervisory authority asks about it.
For those who have mattresses manufactured under their own brand, the distinction between Article 30 and Article 31 is the point to explore now: does this situation fall under the lighter distributor role, or under the manufacturer role with its associated heavier obligations? That distinction will determine a large part of the work ahead.
The legal basis: Article 30 and 31 of the ESPR
These obligations follow from Article 30 of Regulation (EU) 2024/1781 (ESPR), which describes the obligations of distributors, and from Article 31, which regulates in which cases a distributor or trader is treated as a manufacturer. Both articles are part of the chapter on the obligations of market participants in the ESPR.
What to do now
Those who now purchase and resell mattresses can open the conversation with suppliers about the delivery of the digital product passport, and internally examine whether there is a case of own brand or product modification that entails the role of manufacturer. This page will be updated once the delegated act for mattresses has been published and a concrete date is known.
Where this is based on
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
A distributor or trader is someone who purchases mattresses and resells them without manufacturing them or placing them on the market under their own brand — think of a bedding specialty shop, a wholesaler or a hotel buyer who orders directly from a supplier. The ESPR (Regulation (EU) 2024/1781) sets out a number of obligations for this link in the supply chain in Articles 30 and 31. Anyone in doubt about whether this role applies to their own situation should first check this on who is responsible for the product passport of mattresses?the position of distributor is separate from that of importer or manufacturer, and the latter two entail different obligations.
Check whether the product passport is present
Before a mattress is offered, a check is required: is there a product passport, is the QR data carrier present and visible on the product or packaging, and are the mandatory data that should appear on the passport actually there. For a company with 10 to 100 employees, this typically means a fixed control point when new stock arrives, comparable to a quality control that already exists for other aspects of the assortment. This is a check for presence and completeness, not a substantive assessment of the accuracy of the data.
Do not supply without a valid passport
When a mattress is not accompanied by the required passport, it should not be placed on the market or offered. This directly affects the purchasing relationship: a trader who notices that a supplier consistently delivers mattresses without a passport should raise this with that supplier before the stock leaves the shop or warehouse.
Retain and be able to demonstrate data
A distributor or trader should keep the data needed to demonstrate compliance with the requirements available for supervisory authorities. In practice, this means: knowing which supplier supplied which passport, and being able to find this without requiring an extensive archive search.
Passing on information in the supply chain
Questions from a supervisory authority about a specific product should be able to be answered, and where necessary, contact is made with the manufacturer or importer. A distributor is not the person who compiles the content of the passport, but is the person who can pass the question on to whoever does.
Corrective measures when a defect is found
If it is found that a mattress does not comply with the requirements — for example because the passport is missing or incomplete — a distributor should cooperate in this, which may mean that sales of the batch in question are suspended until the defect is remedied.
Where things go wrong in practice
A few situations come up more often than others.
A wholesaler takes on a new supplier without asking about the product passport, because the existing supplier always had this in order and the assumption is that this works the same way for everyone. A spot check shows that the new batch does not provide a passport.
A bedding specialty shop sells mattresses that were purchased via an intermediary outside the usual route — a batch of remaining stock at a sharp price — without checking whether a passport is included. The origin of the product is then also more difficult to determine at the time a question about it comes in.
A hotel buyer orders directly from a manufacturer outside the EU, and incorrectly assumes that the role of distributor does not entail additional obligations here because the order is "just a purchase". Anyone in such a position should check this on my manufacturer is outside the European Union — who arranges the product passport then?, as the division of roles in the supply chain determines who bears which obligation, not the size of the order.
A shop sells mattresses that have been repackaged or are offered under its own store label, without realizing that this may change its own position in the supply chain. Anyone uncertain about this will find more background on I sell mattresses under my own brand — what obligations do I have?.
A trader sells via an online marketplace and assumes that the marketplace itself is responsible for the product passport, while their own role as a trader does not thereby cease. This subject is covered on what does the product passport mean if I sell mattresses via an online marketplace?.
What you can record
- A fixed control point at purchase, in which it is recorded whether the product passport is present and complete upon receipt of a new batch of mattresses.
- An overview per supplier of who provides the passport, and in what manner (QR code on the product, on the packaging, or via an accompanying document).
- Contact details of the manufacturer or importer per product or product line, so that an inquiry from a supervisory authority can be forwarded quickly.
- A brief internal agreement on what happens if a batch without a valid passport is found: who contacts the supplier, and is sales suspended in the meantime.
- A note on products offered under their own name or brand, so that it is clear whether their own role in the supply chain changes as a result.
Anyone who needs a fixed format for this record will find a starting point in the template library of matrapas.eu that aligns with these points. For the question of what actually happens if a passport is missing or incomplete, background information can be found on what happens if I do not have a product passport for my mattresses?.
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, checked by a human on 2026-08-22. Is something wrong? Let us know — corrections are given priority.