Does a boxspring get one product passport or multiple?

What you concretely must do

What is expected of you

A box spring usually consists of a number of separate components that only form a single unit at the customer's location: the base box, the top mattress, and sometimes a separate topper or headboard. The question of whether that will eventually become one product passport or multiple ones is not a minor matter for box spring manufacturers — it determines how you organize your administration, your QR codes, and your labeling.

Determining what the "product" is for which the passport applies

The ESPR provides in Article 1 of Regulation (EU) 2024/1781 that requirements are set per product category designated in a delegated act. For mattresses, that designation is still to come. Until that text is available, it is not established whether a box spring is treated as one assembled product or as a collection of separate products that each fall separately under the rules. For a company with 10 to 100 employees, this means that the setup of the passport process (who provides which data, who attaches the QR code) cannot yet be definitively determined, but that the building blocks — supplier data, material composition per component — can already be collected now. More on the delimitation of what does and does not fall under the regulation can be found at which products in the mattress industry fall under the ESPR.

Ensuring a unique identification code per passport

Article 12 of the ESPR prescribes that a product passport receives a unique identification code. If a box spring is eventually considered as one unit, there will be one code and one passport for the complete bed. If each component is considered separately, then for example the top mattress receives its own code and the base box possibly also. Practically, this means for a production company that the internal article coding (SKUs, order numbers) must align with the eventual passport structure so that an assembler or warehouse employee does not accidentally attach the wrong QR code to the wrong component. For companies that combine components from different suppliers into one box spring, this is an additional point of attention: each supplier may provide its own dataset, which must then be merged into one coherent whole — or must remain side by side as separate passports.

Components that are sold separately, assess separately

A box spring is not always sold as a complete unit. Top mattresses, covers, and loose base units are also offered independently, for example as a replacement part. For that situation, the question is relevant whether such a component in itself already falls within the scope of Article 1. This links to the broader question discussed at does a mattress topper or cover also need its own product passportFor the administration of a company that sells both complete box springs and loose components, this means that there may be two routes running parallel: one for the assembled end product and one for the loose replacement component.

Where things go wrong in practice

One QR code for a product with multiple suppliers. For box springs that are assembled from components of different suppliers, it is sometimes assumed that one of those suppliers will provide "the" data. Without clear agreement, information is missing about, for example, the filling of the base box, while that is necessary for a complete passport.

Confusion between assembly at the customer and assembly at the factory. Some box springs are already combined at the factory into one sales unit, others are delivered in separate boxes and only assembled at the customer's location. That distinction may have implications for the question of whether there is one product or multiple products that happen to be sold together — and thus for the question of how many passports are needed.

Reusable components that are ordered separately as replacements. A customer who replaces only the top mattress of his box spring after a few years receives a new component with potentially its own passport, while the rest of the bed still carries the old passport (or no passport, if the bed predates the obligation). Companies that fail to think this through run the risk that the customer ends up with two separate, incompatible datasets.

Stock and white-label models. Companies that sell the same underbox under different brand names sometimes assume that one passport can suffice for all variants. As long as it remains unclear how the delegated act handles composite products, that is an assumption that may require adjustment afterwards.

Assumptions about hotel mattresses in box spring form. When supplying the hotel industry, box springs are often delivered in bulk and without standard packaging. The question of how the passport is linked in this case — per bed, per room, per order — is addressed under the product passport also applies to mattresses supplied to hotels, and deserves attention from companies serving this segment.

What you can record

• An overview of the components that make up your box spring models, with the supplier and available material data for each component.
• Internal agreements with suppliers on who provides which data and in what format, so that these can later be easily combined into a passport.
• A list of models that are sold both as a standalone component and as part of a composite product, making clear where duplicate or missing passports could potentially arise.
• Documentation of the assembly method (in the factory or at the customer) per product line, as an aid for a later assessment of what constitutes "the product".
• A dossier with the current status of the delegated act for mattresses, so you do not have to constantly research the legislation yourself — see also the explanation of what a delegated act is and why it determines what you must do.
• A link between your internal article coding and the future passport structure, so that conversion to unique identification codes according to Article 12 of the ESPR can take place later without restructuring your systems.

Once the delegated act for mattresses is published, this will be supplemented with information on how box springs and other composite beds are concretely treated. Until that time, the preparatory work — having data per component in order — is the step that makes sense now, regardless of how the final classification turns out.