How often must I update the data in the product passport?

No fixed period, but keep it current when changes occur

The ESPR does not prescribe a fixed calendar period — nowhere does it state that the passport must be updated "every year" or "every two years". What does follow from the regulation is that the information in the passport must remain accurate and up-to-date as long as the passport exists. This is therefore not a periodic obligation but a continuous one: as soon as something changes that is relevant to the data in the passport, that passport must reflect that change. For a mattress, this can include matters such as an adjustment in the material composition of a production line, repair or reuse of components, or a change in the owner of the product upon resale. As long as nothing changes, there is no reason to update the passport.

Which data this applies to, and which it does not

This principle applies to the data that is actually included in the digital product passport: the information that is accessed via the QR code or comparable data carrier and that is linked to the unique product identification. It does not apply to general marketing information, product catalogues or data that is published separately from the passport — different rules or no rules under the ESPR apply to those. Nor does it apply retrospectively to mattresses that have already been placed on the market before the obligation for this product category comes into force; those simply fall outside the scheme. And in practice it applies especially to data that can change: static data (such as the composition at the time of production) does not need to be confirmed repeatedly if nothing has changed.

No date set yet for mattresses

For mattresses, it has not yet been established when the obligation for a digital product passport comes into force, and therefore also not from when the obligation to keep data up-to-date will apply in concrete terms. This will be regulated in a product-specific delegated act under the ESPR, which is expected for mattresses in the work plan for the period 2025-2030, with expected publication in 2028. As long as that delegated act is not in place, no concrete obligations under Articles 9 and 10 of the ESPR apply to mattresses. Once the act is published and more becomes known about the date on which mattresses fall under the scheme, that will be stated here.

How to approach this in practice

Anyone thinking now about maintaining passport data is well advised to first map out which data about a mattress can change over time — think of the origin of raw materials, possible repair or refurbishment steps, or changes in ownership upon resale of, for example, hotel mattresses. Next, it is important to establish who signals that change: the manufacturer in the case of a change in production, the importer in the case of a new supplier, or the specialist retailer in the case of information that only becomes known at the time of sale. That information must then be passed to the party managing the passport, so that the data is updated under the same unique identification rather than creating a new, separate passport. Finally, it is practical to keep track of when and why a piece of data was adjusted — not because the ESPR prescribes that as such, but because a traceable change history helps to be able to demonstrate afterwards that the passport reflects the current situation.

The legal basis: Articles 9 and 10 ESPR

All of this follows from the combination of Article 9 and Article 10 of Regulation (EU) 2024/1781 (ESPR). Article 9 describes the general structure of the digital product passport, including the link to a unique product identification which allows data on a product's lifetime to be added to or modified in the same passport instead of requiring a new passport. Article 10 describes the requirements for the information itself, including that it must be accessible, complete and up-to-date and remain so. From these two articles together it follows that the obligation is not tied to a fixed deadline, but to the moment when the underlying situation changes. Product-specific details for mattresses — such as any additional requirements on update frequency or update responsibility — must still be clarified in the delegated act that will flesh out this regulation for mattresses.

If you are a manufacturer, importer or specialised retailer and are already gathering data on the mattresses being sold, it is advisable to keep that data structured and communicate changes to the party hosting the passport — so that the passport gives an accurate picture as soon as the obligation takes effect, instead of requiring a catch-up exercise.

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

The ESPR regulates in Article 9 and Article 10 what a digital product passport must be capable of and what requirements apply to it, but a fixed update interval — for example "once per year" or "within thirty days of any change" — is not specified with a concrete number. What is there, however, is a principle: the data in the passport must correspond to the product as it is on the market. For the practice of a mattress manufacturer or importer, this translates into a number of recognizable obligations.

The link between product and passport must remain correct.

The passport belongs to a specific product or a specific product group. As soon as something changes in the composition, the construction or the materials used, the information in the passport no longer matches what is actually being sold. For a company with 10 to 100 employees, this means that product changes — a different foam supplier, an adjusted density, a different flame retardant — are not merely an internal note for production or procurement, but also a moment when someone must check whether the passport is still current. This requires a fixed roadmap: who in the company identifies a change, and who then implements it into the passport.

Data coming from third parties must be documented.

A mattress passport consists of data that often comes from different parties: the foam supplier, the textile supplier, the producer of flame retardants. When one of those parties makes a change — a different composition, a different certificate — the responsibility to flag that effectively shifts to the person who has the passport compiled. For a mid-sized company, this means that the supplier relationship does not end with the procurement agreement, but must include an information agreement about changes that are relevant to the passport.

The passport remains accessible for ten years, even if the product changes.

Article 10 sets requirements for the accessibility of the passport over a longer period. For a mattress that is hosted via matrapas.eu for ten years, this means that a buyer who consults the passport again years later — for example at resale, repair or end of life — must find data that matches the product as delivered at the time. This is a different task than "making it current once": it is about a passport that remains reliable throughout its entire term, even when the underlying product model has since been further developed or taken out of production.

Components that by definition change require their own rhythm.

Not all information in the passport is static. How do I substantiate the expected lifespan of a mattress? is a question whose answer can shift once new test results or practical experience become available. Instructions for maintenance or repair can also change when new repair methods emerge or when earlier advice proves not to work in practice. For this type of information, it is practical to distinguish between information that is fixed at production (such as material composition) and information that can evolve with knowledge that becomes available after sale.

Where things go wrong in practice

A frequently encountered situation is the supplier switch that is not reported. A manufacturer switches to a different foam supplier because the original supplier cannot deliver, the quality is comparable, and nobody thinks about the passport because the "product simply remains the same". The passport then refers to a density or composition that no longer matches what is in the mattress.

A second situation: a flame retardant is replaced due to a change in regulation, but the change is only implemented in the production instructions and not in the passport. Questions about which flame retardants must I report in the product passport? are then not asked once at the first compilation, but each time the composition changes.

A third situation arises with product lines that are gradually being phased out. A model is no longer produced, but there are still units at the specialist retailer. The passport remains active because the product is still being sold, while information about the recycled material supplier has meanwhile changed for the successor — and no one has documented which version of the data corresponds to which production batch.

A fourth situation arises when measurement methods change. If the way in which a value is determined changes — see also the question according to which method must I measure the values for the passport? — a previously measured and published value may no longer be comparable with a new measurement, without this being explained in the passport.

A fifth, less visible situation: the company itself changes. A merger, takeover, or change of importer means that the party responsible for the accuracy of the passport changes, while no one has agreed who will handle the update after the transition.

What you can record

An internal change process setting out who identifies a product change (procurement, production, quality) and who communicates that to the party managing the passport.
Agreements with suppliers about reporting changes in material, composition or certification, for example as part of the purchase agreement.
An overview of which passport elements are linked to which production batch or production period, so that when a change occurs, it is clear which earlier passports can remain unchanged.
A documented procedure for updating information that can by definition change, such as maintenance advice — see also do I need to indicate how to maintain or have a mattress repaired — and the substantiation of the expected service life.
A note upon takeover, merger or change of importer about who assumes responsibility for the passport.
A file in which, for each change, it is documented when and why a data item in the passport was amended, so that upon inspection it is traceable how the current version was created.

As soon as the delegated act for mattresses is published and sets a concrete deadline for updating, this will be supplemented here.

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.