How do I check whether my supplier's data is correct?

Verification revolves around the method, not the figure

Whether data from a supplier is correct is in practice difficult to establish by looking solely at the outcome — a figure about lifespan, material composition or disassembly says little in itself. What can be verified, however, is the way in which that figure was derived. Article 39 of the ESPR (Regulation (EU) 2024/1781) establishes that test, measurement and calculation methods must be reliable, accurate and reproducible. This means that a supplier can in principle demonstrate which method or standard was used and that another party, using the same method, should be able to arrive at a comparable result. Article 40 adds a second criterion: the method must not be designed in such a way that a product behaves differently during a test than under normal use, and performance must not deteriorate once the product has been approved or placed on the market. For those receiving supplier data, verification therefore comes down to checking whether there is a method behind the figure, and whether that method holds up.

For product data in the passport, not for commercial claims

These two articles concern the data that ultimately appears in the digital product passport: the technical and environmental information about the mattress itself, such as material composition, recyclability or other characteristics that will be designated by the delegated act for mattresses yet to be published. They do not cover marketing texts, pricing agreements or delivery terms — different rules apply to these, and they fall outside the scope of Articles 39 and 40. It is also important to note who bears the obligation: Articles 39 and 40 are directed at the person placing the product on the market and establishing the data, typically the manufacturer or importer. A specialist bedding retailer or hotel purchaser receiving data is not the one who must perform the measurement method, but can check whether the source of the data can substantiate that process. That distinction — who establishes the data, and who receives and uses it — determines what "verification" means in practice for each party.

No fixed date yet, but a work plan in progress

There is no definitive date yet for when specific test and measurement methods for mattresses become mandatory. According to the ESPR work plan 2025-2030, the delegated act for mattresses is expected around 2028, but this is a planning date and not a binding obligation. Once the act is published, the exact date will be stated here. Until then, the general provisions of the ESPR itself — including Articles 39 and 40 — apply as a framework, but the mattress-specific specification of which methods must be used and which data must be verified is missing. This means that a supplier cannot currently be required to use a method that has not yet been established, and that verification at this point mainly consists of building a file: documenting which sources and methods a supplier is already using, so that later, when the delegated act is in place, it can be quickly checked whether these comply.

What to do: from question to file

The first step is to ask which method, standard or test report underlies a given value, rather than taking the figure itself at face value. A supplier who can refer to a test report, a certificate from an accredited laboratory or a common industry standard offers more certainty than a supplier who only provides a number without a source. The second step is to look at plausibility: if a value deviates strongly from comparable products in the same category, that is a reason to ask further questions, not to accept the data uncritically or reject it outright. The third step is to pay attention to signals that touch on Article 40: results that are notably favourable compared to what would be expected under normal use may indicate a test setup that is not representative. The fourth step is to document: keep what the supplier has provided and on what basis, so that there is a trail to follow back. Matrapas.eu records the supplied data when compiling the product passport, which keeps this file accessible to the user throughout the hosting period.

What this is based on

The obligation to use reliable, accurate and reproducible test, measurement and calculation methods is set out in Article 39 of the ESPR (Regulation (EU) 2024/1781). The prohibition on circumvention and on deterioration of performance after approval is set out in Article 40 of the same regulation. Both articles are general provisions that apply to products under the ESPR; the concrete implementation for mattresses follows from the delegated act yet to be published.

If you are already receiving data from a supplier now, it is best to start by asking about the underlying method and recording it, so that there is a basis for later testing against the specific requirements that the delegated act for mattresses will set.

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 manufacturer assembling a digital product passport does so largely with data from others: the supplier of the foam, the springs, the ticking, the adhesives. That data is incorporated into the passport, but responsibility for its accuracy does not automatically transfer to the supplier. The ESPR (Regulation (EU) 2024/1781) sets requirements for how product information is substantiated and how to prevent that information from giving a misleading picture.

Substantiation according to the correct method

Article 39 of the ESPR addresses the test, measurement and calculation methods used to demonstrate that a product meets the requirements. For a company with 10 to 100 employees, this means in practice that a claim about a mattress — a percentage of recycled material, an emission value, a durability indication — is not simply adopted because the supplier says so. There must be a method behind it that aligns with what is prescribed or customary for that type of data. If a company does not have its own laboratory, it depends on what the supplier provides for this substantiation — and that is precisely the point where verification is needed.

No circumvention or concealment of performance

Article 40 of the ESPR aims to prevent the actual performance of a product from being circumvented or concealed, for example by scoring well only under certain test conditions while performing differently under normal use. For a mattress manufacturer, this means that a notably favourable figure from a supplier — an exceptionally low emission value, an unusually high recycling rate — is reason to ask further questions about the measurement conditions, not to state the figure without further inquiry.

What this means in practice for the manufacturer's role

These two articles address the product and claims about it, not specifically the relationship between manufacturer and supplier. But because the manufacturer is the one who assembles and publishes the passport, the question "is this correct" falls to the manufacturer in practice. This is not a legal technicality — it is where assembling a passport differs from filling in a form. Which data must I request from my mattress supplier? is a first step; what happens with that data after that is what this deepening is about.

Where things go wrong in practice

A figure without a source. The supplier provides a percentage or value, but not the underlying test or calculation. The figure is adopted because it "must be correct" — until someone asks about it and no one can explain how it was determined.

Test conditions that are not disclosed. An emission value or a durability claim has been measured under specific conditions (temperature, load, test duration), but those conditions are not provided. Without that context, it cannot be established whether the value is representative of normal use of the mattress.

Data from different suppliers that contradict each other. The foam comes from supplier A, the springs from supplier B, and each provides their own statement on recyclability or material composition. When these two do not align — or cannot even be combined into a coherent passport — a problem emerges that only becomes apparent when assembling the passport. How do I combine data from different suppliers of foam and springs into one passport addresses this situation specifically.

A favourable figure that is not questioned. A supplier provides a value that is clearly better than what comparable suppliers report. Instead of seeing this as an advantage, this is precisely the moment to ask how the value was determined — precisely because Article 40 of the ESPR addresses the prevention of a concealed or incomplete picture.

Procurement from outside the EU without comparable substantiation. For mattresses or components sourced from outside the EU, the documentation on test and measurement methods is not always prepared according to the same standards. What does the product passport mean if I import mattresses from outside the European Union? It addresses what this means for the importer's position.

What you can record

The test method or calculation method behind every figure that the supplier provides — not only the result, but also how it was determined.
The test conditions under which a value was measured, especially for emission, discharge or durability data.
Date and version of the informationso that when the data is updated, it is clear which value applied when.
Contact details of the person at the supplier who can clarify the information, in case a question arises about it.
A fixed agreement in the purchase contract on the substantiation that is provided with each data delivery. How do I document the supply of passport data in my purchasing contract? describes how this is arranged in practice.
A file per component (foam, spring, ticking, adhesive) instead of one consolidated document, so that when a supplier changes, it is clear which file is being replaced. This aligns with the question of whether the product passport remains accurate if a different supplier of mattress material is used.
A fixed procedure for what to do when data is missing or not provided — this is set out in My supplier does not provide the data — what can I do?

Recording these points is not a matter of legal completeness for the sake of completeness, but of demonstrability: if a figure in the passport is questioned, the difference between "we checked this at the time and this is why" and "the supplier said it was like this" is exactly the difference between a defensible passport and a vulnerable one.

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.