Does the digital product passport apply to my mattresses?

What you concretely must do

Mattresses are among the product groups mentioned in the European Commission's work plan as candidates for a digital product passport. The ESPR (Regulation (EU) 2024/1781) establishes the scope in Article 1: the regulation applies in principle to almost all physical products placed on the EU market, and Article 9 provides that the Commission shall adopt a delegated act for each product group that makes concrete what requirements apply and from when. For mattresses, that delegated act does not yet exist. This means that the question "does it apply to my mattresses" cannot currently be answered with a simple yes or no — not because the answer is complicated, but because it has not yet been determined.

What is certain: the ESPR is the framework regulation that creates the possibility, and mattresses are on the list of product groups that the Commission is seriously considering. As soon as the delegated act for mattresses is published, it will be specified here which mattresses are covered and from when. Until then, preparing is prudent, but there is no legal obligation to maintain a passport now.

What is expected of you

Monitor whether the delegated act for mattresses has been published

For a company with 10 to 100 employees, this means in particular: designate someone to follow developments and do not wait until a customer or supervisory authority asks about it. This could be the quality manager, the procurement officer or the person already responsible for CE marking and compliance. Further explanation of what such an act is exactly and why it is decisive can be found on the page about what a delegated act is and why it determines what you must do.

Establish whether your products fall within the intended product group

Not every product with springs and filling is automatically called a "mattress" in the sense of a future regulation. Toppers, covers and box springs may be treated differently from the mattress itself. For a manufacturer or importer, it is practical to already map out which items in the assortment are sold as a mattress, which as an accessory, and which as an assembled product. That overview saves time once the definitions are official. More on this demarcation can be found under which products in the mattress industry fall under the ESPR and under the question of whether a mattress topper or cover must also have its own product passport.

Put data in order that will be needed later

Even without established obligations, it is useful to examine what product data a company already records: material composition, origin, warranty periods, maintenance instructions. Much of what will eventually have to go into a passport often already exists in internal systems, just not in one place. For an impression of the type of data that is expected, the page on what data will be included in the product passport for mattresses is a good starting point.

Assess whether sales channels play a role

For companies that sell to hotels, bed specialty shops or through their own web shops, the channel may influence who takes on which role in the passport process that will then be mandatory. This applies equally to sales to business customers as to consumers. See on this subject whether the product passport also applies to mattresses supplied to hotels.

Where things go wrong in practice

A common misconception is that "the ESPR" and "the product passport for mattresses" are the same thing and would therefore already be mandatory because the ESPR has already entered into force. The ESPR is the framework; the specific obligation for mattresses arises only with the delegated act for that product group.

A second situation: companies assume that small players will not be affected without checking the wording. Company size plays a role in the ESPR system for certain obligations, but not automatically for all. See the explanation under whether the product passport also applies to small companies.

A third pitfall: assuming that a box spring is treated as a single unit, while the mattress and base are separate products with their own characteristics. This directly raises the question whether a box spring receives one passport or multiple.

A fourth situation arises in the trade of second-hand mattresses or private sales: companies and individuals wonder whether an existing passport remains valid, expires, or must be redrawn. See on this subject the pages on selling used mattresses and on private sales between consumers.

A fifth: delaying all preparation until the date is confirmed, which means that when the delegated act is published, there is little time left to collect data that were actually available long ago, but dispersed across different departments or suppliers.

What you can record

• An overview of the company's own assortment, divided by mattress, topper, cover and assembled product (such as box spring), so that it is clear which article will fall under which rule.
• A list of product data already being kept (material, origin, warranty, maintenance) and where that data is currently located.
• An indication of who within the organisation is responsible for monitoring the delegated act for mattresses.
• An overview of sales channels (private, commercial, hotel sector) and the role the company plays in them: manufacturer, importer or reseller.
• Correspondence with suppliers or sub-suppliers about material origin, so that this data does not have to be requested retrospectively.

For a broader picture of what the ESPR changes for the sector as a whole, and not just for the passport, the page on what the ESPR changes for the mattress industry is a useful starting point. And for those who want to first familiarise themselves with the instrument itself, the explanation what a digital product passport for mattresses is provides a basis to work from.