What is the register of digital product passports and what must I enter in it?
A central EU register alongside the Digital Product Passport itself
The register of digital product passports is a central database that the European Commission establishes and manages pursuant to Article 13 of the ESPR (Regulation (EU) 2024/1781). It does not contain the full passport data of a mattress, but rather a limited set of identifying data that allows market surveillance authorities and customs to locate a product and its corresponding passport. The passport itself — with the comprehensive product information on materials, composition, maintenance and end-of-life — remains hosted by a service provider such as matrapas.eu or by the manufacturer itself; the register is the reference index to it, not the storage facility for all data.
For manufacturers and importers, not for retailers
Article 13 is directed at the economic operator who places a product on the market or puts it into service under the ESPR: typically the manufacturer or the importer. That party is the one who arranges for data to be entered into the register before a product is placed on the market. A bed specialist retailer that resells mattresses that are already equipped with a passport and registration does not need to enter anything into the register itself. It is also important to note the distinction with Article 14: that article establishes a separate web portal through which the public — consumers, researchers, supervisory authorities — can search for certain passport data. The register (Article 13) is thus the technical infrastructure for identification and supervision; the web portal (Article 14) is the access point for anyone wishing to consult data. Both are not a replacement for the passport that is accessible via the QR code on the mattress itself.
The date is not yet fixed
When the register for mattresses must actually be put into use depends on the delegated act that establishes the product requirements and the passport for mattresses. That act has not yet been published; according to the Commission's work plan for the period 2025-2030, it is expected around 2028, but this is a schedule and not a fixed date. Once the act is in place, it will also specify from which point manufacturers and importers of mattresses must arrange for data to be entered into the register. Until such time, there is no legal obligation for mattresses to enter anything into the register — Article 13 itself already describes how the register works, but the implementation per product group is handled through the delegated acts.
What a manufacturer or importer can prepare now
The order in which this is typically approached: first ensure that your own product data is in order — materials, composition, origin, maintenance instructions — because this is the basis for both the passport and the identifying data that will later appear in the register. Next, it is useful to look at which unique identification codes are already in use within your own organisation, such as article numbers or GTIN codes, because the register works with these types of identifying keys to link a product and its corresponding passport. Subsequently, it is a matter of waiting until the delegated act for mattresses becomes known: it will determine which data exactly must be entered into the register and at what point. A service provider hosting the passport, such as matrapas.eu, can technically arrange the link between the hosted passport and the register once that obligation arises, but the manufacturer or importer remains responsible for the accuracy of the data that is ultimately registered.
What this is based on
That a central register is established and what its basic function is are set out in Article 13 of the ESPR (Regulation (EU) 2024/1781): the register is set up and maintained by the Commission, and serves to make products and their passports identifiable for supervision and customs purposes. The distinction with the publicly accessible web portal follows from Article 14 of the same regulation, which describes a separate access point for consulting data from digital product passports. For the precise content and date of application to mattresses, the delegated act for this product group is decisive; until it is published, there is no additional source from which to derive a concrete date or dataset.
What to do
At present, the most important step for a mattress manufacturer or importer is to have their own product data and identification codes in order, so that they are ready as soon as the delegated act for mattresses is published. This page will be updated as soon as that act is published and it becomes clear which data must be entered in the register and from when. For the current legislative text of Articles 13 and 14, the official publication on EUR-Lex can be consulted.
Where this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 13 (register of digital product passports)
- Regulation (EU) 2024/1781 (ESPR), Article 14 (web portal for data in the digital product passport)
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
Article 13 of the ESPR (Regulation (EU) 2024/1781) provides that a single European register shall be established to store certain data from digital product passports. That register shall be managed by the European Commission, not by individual manufacturers. For a mattress manufacturer or importer, this means above all that data already contained in the passport must also be retrievable and exchangeable via this register — it is a layer above the passport, not an additional document that you must prepare separately.
Providing the correct data to the passport, suitable for registration
The basis of the register is the data already contained in the digital product passport of the mattress. What exactly from that passport will end up in the register will be worked out further, but the logic is that this concerns identification and compliance data, not the complete product information. For a company with 10 to 100 employees, this means that the data provided to the passport — such as the unique identification code of the product — must be in order and consistent, because that same data will be used elsewhere. If you struggle with assigning those codes to different mattress models and variants, you will find background information at how to give each product a unique identification code.
Ensuring the passport is aligned with the web portal
Article 14 of the ESPR describes a web portal through which data from digital product passports become accessible, including for market surveillance and customs. This portal is closely linked with the register from Article 13: it is the technical gateway through which authorities can retrieve data. For the manufacturer or importer, this means that the passport cannot stand alone, but must be technically connected to the infrastructure established by the Commission for this purpose. This is one of the reasons why many companies do not attempt to build this themselves, but instead entrust it to a platform that handles the data carrier and the connection. If you already use an ERP or inventory system, you can read how to link the product passport to your own system.
Keeping data current for as long as the passport exists
Because the register and the web portal continuously provide access to data from the passport, the quality of that connection is not a one-time exercise. A mattress that can be followed on the market for ten years requires a passport that must remain available and up-to-date for just as long. For a company, this means that someone must be responsible for maintaining passport data, even when a product has not been manufactured for a long time. More information about the retention period can be found at how long a product passport must remain available.
Where things go wrong in practice
A first situation where things go wrong: a manufacturer thinks that the register is a separate form that must be filled in independently of the product passport, and spends time on it that would be better spent on the quality of the passport itself. The register builds on the passport, not alongside it.
A second: companies assume that they themselves must enter data into the register, whereas the intention is that this happens through the connection of the passport to the central infrastructure. If you try to arrange this yourself without the correct technical connection, you risk that data does not reach where it should.
A third situation: a mattress receives a QR code that refers to a passport, but the underlying identification code is not unique or is reused for different variants. Because the register depends on unambiguous identification, this leads to confusion that cannot be easily remedied by a correction afterwards. Background information about the link between code and passport can be found at what GS1 Digital Link is and whether it is necessary for the product passport.
Fourth: an importer thinks the register is only relevant for large manufacturers with many models, and pays no attention to it for customized products. Especially for made-to-measure mattresses, where each combination of sizes and materials may require its own passport, a clear structure is needed to prevent passports and register data from no longer belonging to the correct product. See about this how the product passport works for made-to-measure mattresses.
Fifth: a company stops a product line or ceases to exist, and no one has laid down who remains responsible for the data that must remain accessible via the register and the web portal. This is not a theoretical risk for a sector in which companies are taken over or close down; see what happens to the product passport if a company stops.
What you can record
- An overview of which unique identification code belongs to which mattress model and which variant, including the date on which this was assigned.
- A documented agreement with the hosting party of the product passport regarding the technical link to the web portal of Article 14 of the ESPR, so that data flows correctly.
- An internal contact point for keeping passport data up to date, also for products that are no longer produced.
- An overview of which data per mattress has been submitted for the passport, so that during an inspection it is quickly clear which information comes from where.
- A backup agreement in case the hosting party of the passport data stops or changes service provider; see what happens to passport data if the hosting party stops.
- For multiple passports per product (for example due to additional legislation alongside the ESPR): an overview of how these passports relate to each other, so that the register is not fed with contradictory data. See how multiple product passports for one product work together.
The exact technical specifications of the register and the web portal will be further developed by the European Commission. What is described here is based on Article 13 and Article 14 of the ESPR (Regulation (EU) 2024/1781); for the full and current text, reference is made to the official source via EUR-Lex.
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.