My manufacturer is outside the EU — who arranges the digital product passport then?

The importer or an authorized representative arranges this

If the manufacturer is located outside the EU, responsibility for the digital product passport lies with the person who places the mattress on the EU market. This is usually the importer, or an authorized representative designated by the manufacturer for this purpose. The manufacturer itself remains the source of technical data — materials, composition, origin — but the party that actually introduces the product into the EU is responsible for ensuring a passport exists before the product is sold.

For whom this applies and for whom it does not

This topic concerns mattresses manufactured outside the EU and subsequently sold in the EU. It therefore does not concern mattresses manufactured within the EU, even if components or raw materials come from outside the EU — in that case the EU manufacturer is simply responsible themselves. It also does not concern the question of who technically compiles or hosts the passport (that can be a party such as matrapas.eu, regardless of where the manufacturer is located), but rather who is legally responsible for ensuring the passport exists and is correct. An authorized representative is not automatically required either: that role only arises if the manufacturer outside the EU has actually designated someone. If this has not happened, responsibility shifts to the importer who places the mattress on the EU market.

When this will apply

A fixed date for mattresses does not yet exist. The ESPR (Regulation (EU) 2024/1781) is the framework regulation; a delegated act must still be adopted for mattresses to establish the precise requirements and the date of application. According to the European Commission's work plan for 2025-2030, that delegated act for mattresses is expected around 2028, but this is a plan and not a commitment — the actual publication date may shift. As soon as that act is published, the exact date will appear here. Until then, nothing changes in practice for mattresses: the obligation for a digital product passport only arises with the specific act for this product category, not with the ESPR itself.

How this works in practice

An importer bringing mattresses from outside the EU is well advised to already map out which data the manufacturer can supply: material composition, origin of raw materials, any chemical substances, repair and recycling information. This is the basis on which the passport will be compiled, and such data is often not automatically available — a manufacturer outside the EU does not always have the same reporting practices as a European producer. A second step is to verify whether the manufacturer has designated an authorized representative, or whether that role will in fact fall to the importer itself. If there is no authorized representative, it is practical to make arrangements with the manufacturer in good time so that data does not have to be requested again with each shipment. A third step is to consider your own position in the supply chain: an importer who buys directly from a manufacturer outside the EU has a different role than a wholesaler who buys from a European importer — in the latter case, the passport responsibility already lies with that earlier link. For bed specialists and hotel procurement who resell mattresses without importing themselves, it is generally the case that responsibility has already been assigned earlier in the chain, with the importer. Nevertheless, it is advisable to verify with your own supplier which party fulfills that role, so that there is no confusion when selling about where the passport comes from.

What this is based on

Article 29 of the ESPR (Regulation (EU) 2024/1781) describes the obligations of importers, including ensuring that the product is accompanied by the required information and documentation before it is placed on the market. Article 28 of the same regulation governs the role of the authorised representative: a manufacturer outside the EU may appoint in writing a party within the EU to perform specific tasks on its behalf, including tasks related to the product passport. Both articles apply within the broader framework of the ESPR; the precise implementation for mattresses — which data, which format, which entry date — follows from the delegated act that has not yet been published.

What to do now

If you are already importing mattresses from outside the EU or planning to do so, it is best to contact the manufacturer in advance about which product data are available and whether an authorised representative has been appointed. Once the delegated act for mattresses has been published, the definitive date and precise content of the obligation will be added here — this page will then be updated.

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 mattress manufactured outside the EU and placed on the European market is not without a passport — only the responsibility for it lies with a different party than the manufacturer itself. The ESPR (Regulation (EU) 2024/1781) provides for this in two ways: via an authorised representative appointed by the manufacturer, or via the importer who actually brings the mattress into the EU. Who exactly is responsible depends on the structure that has been set up, and that is precisely where things often go wrong. See also Am I an importer or manufacturer according to the ESPR? for the basic classification.

The authorised representative

Article 28 of the ESPR describes the possibility that a manufacturer outside the EU appoints an authorised representative. That is a party within the EU who is authorised in writing to perform certain tasks on behalf of the manufacturer, including tasks related to the product passport. For a bed specialist or hotel purchasing department that sources mattresses from a manufacturer outside the EU, it is practically relevant to know whether such a representative exists and what exactly that party may do. A written mandate is the core of this: without that mandate, there is no representative within the meaning of Article 28, however the party may otherwise be named.

The obligations of the importer

Article 29 of the ESPR describes the obligations of the importer — the party that places the mattress on the European market from a country outside the EU. For a company of 10 to 100 employees that purchases mattresses directly from a manufacturer outside the EU, this usually means that the company itself fulfils the importer role, with the associated obligations regarding the product passport. That is a different position than that of a party that merely resells mattresses within the EU. The difference between these two roles is explained in What obligations does a distributor or trader of mattresses have?

Verifying that the passport is actually present

Regardless of who actually compiled the passport, the question remains whether it is with the mattress when it enters or is sold on the EU market. For an importer, that is a practical control point: checking whether the QR data carrier is present and whether the data in it corresponds with the mattress being delivered, before the product goes further down the chain.

Where things go wrong in practice

A number of situations regularly occur with mattresses coming from outside the EU:

No authorised representative has been appointed. The manufacturer outside the EU has not appointed any party within the EU with a written mandate under Article 28. The Dutch purchaser then, often without clearly realising it, takes on the role of importer with the associated obligations under Article 29.

An intermediary claims to be a representative without a mandate. There is sometimes a contact person or agent who presents themselves as a point of contact for the passport, but there is no written mandate under Article 28. Upon later inquiry, that party turns out to have had no authority to establish anything on behalf of the manufacturer.

The passport contains data that does not match the mattresses actually delivered. Manufacturers outside the EU sometimes work with documentation that has been drawn up for a different market or an earlier version of the product. If there is doubt about the accuracy of the data, who is liable if there is incorrect information in the product passport of a mattress is relevant to read.

Multiple importers within the EU, no clarity on who is responsible. When a manufacturer outside the EU supplies different European purchasers, and those purchasers resell the mattresses, confusion arises about who fulfils the importer role for which batch of mattresses. That is a question that relates to Who is responsible for the product passport for mattresses?

Private label via a manufacturer outside the EU. A company has mattresses manufactured under its own brand by a manufacturer outside the EU, without first agreeing who will compile the passport and who will fulfil which role. That relates to the question dealt with in who is responsible for the passport if I have mattresses made under my own brand

What you can record

The written mandate of the authorised representative, if one exists — with a clear description of which tasks the representative performs on behalf of the manufacturer.
Contact details and role determination of the manufacturer established outside the EU, the possible representative, and the importer, so that when there is a question about the product passport it is clear who is to be contacted and who must respond.
The underlying product data which the manufacturer established outside the EU has supplied, with a date and version, so that a later product passport can be traced back to the data on which it is based.
A control moment upon arrival of the mattresses, in which it is documented that the QR data carrier is present and the data have been checked before the product proceeds further through the supply chain.
Agreements on changes to the mattress, such as a different foam composition or filling, and who is responsible for communicating that — see also do I need to update the product passport if I change the foam or filling

Matrapas.eu can provide subscribers with a template in which these roles and agreements are documented, so that when there is a question from a trader, a competent authority or a customer, there is a clear overview of who has taken which step.

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.