What does the product passport mean if I import mattresses from outside the EU?

Importers receive their own obligations upon import

Whoever imports mattresses from outside the EU and places them on the EU market is considered an importer under the ESPR (Regulation (EU) 2024/1781), and this role comes with its own obligations regarding the digital product passport. This is not an obligation that rests solely with the manufacturer in the third country: the importer who actually places the product on the EU market bears their own responsibility for this. This means, among other things, that it is checked whether the passport exists, whether it complies with what is required, and whether it is accessible before the product reaches the EU market. For imports from outside the EU, an additional layer is added: customs can involve the passport in the inspection of goods entering the EU.

For whom this applies, and for whom it does not

This obligation applies to the party acting as an importer: the party established in the EU that places a mattress from a third country on the EU market for the first time. This is a different role from that of manufacturer (who makes the product, even if that happens outside the EU) and a different role from that of distributor (who trades a product that has already been placed on the EU market, for example a wholesaler or shop that purchases from an EU supplier). For a bed specialist retailer that purchases mattresses from a manufacturer already established in the EU, this specific importer obligation does not apply — that retailer acts as a distributor, not as an importer. This page concerns the situation in which a party itself sources mattresses from outside the EU and places them on the EU market for the first time, or acts for this purpose on behalf of a manufacturer outside the EU.

The date is not yet fixed

When these obligations will concretely apply to mattresses depends on when the delegated act for this product group is published. That date is not yet fixed. Until the time that delegated act enters into force, the existing rules on import and market surveillance apply, without the additional obligation to provide a digital product passport. Once the delegated act is published and the deadline specified in it has elapsed, the obligation for mattresses will take effect. This page will be updated as soon as that date is known.

What this means in practice

For those importing mattresses from outside the EU, the first question is which role is performed in doing so: does the party act as an importer (first party to place the product on the EU market) or as a distributor of a product that has already been imported by another party? Only in the first case do the importer obligations under Article 29 apply directly.

If an importer role is involved, the next step is to verify whether the manufacturer or supplier outside the EU has provided the data for the product passport, and whether that data complies with what is required for the product group. Matrapas.eu compiles the passport based on the data provided by the manufacturer or importer, hosts the passport, and provides the QR data carrier — but the data itself, and the question of whether it is complete and correct, remain the responsibility of the party providing it.

Subsequently, it is important that the passport is accessible at the moment the mattress reaches the EU market, not only afterwards. Customs can involve the digital product passport in the inspection of goods entering the EU, as provided for in Article 15 of the ESPR. This makes it practically different from purchasing within the EU: when importing from outside the EU, there is a moment at the border when the passport must already be available, whereas in trade between parties within the EU that moment does not exist in the same way.

Finally, it is advisable to keep the underlying documentation available — which shows how the data in the passport was produced — even after placing it on the market, because supervisory authorities may ask for it.

This follows from: Article 15 and Article 29 ESPR

The obligations of importers regarding the digital product passport are set out in Article 29 of Regulation (EU) 2024/1781 (ESPR). The role of customs in controlling products entering the EU, in conjunction with the digital product passport, is set out in Article 15 of the same regulation. Both articles form part of the general ESPR framework; the concrete requirements that will apply specifically to mattresses will come in the delegated act for this product group, which has not yet been published.

What to do now

Anyone importing mattresses from outside the EU or planning to do so should first establish whether the role of importer is fulfilled within the meaning of the ESPR, and then contact the manufacturer or supplier outside the EU about which data is available for the product passport. Matrapas.eu can compile the passport and provide the QR data carrier on the basis of that supplied data once the delegated act for mattresses enters into force; for the exact requirements and entry date, the official text of the ESPR and the corresponding delegated act remains the source to consult.

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

Whoever brings mattresses from outside the EU onto the European market is an importer under the ESPR. This is a distinct role with its own obligations, separate from what the manufacturer in China, Turkey or Vietnam does or does not arrange. The obligations described in Article 29 of the ESPR (Regulation (EU) 2024/1781) for importers apply to mattresses in addition to the question of whether the product falls under the regulation at all — something that is elaborated on the page Which products in the mattress industry fall under the ESPR? further.

Checking whether the passport exists and is correct

An importer places a mattress on the market only if a digital product passport accompanies it that meets the requirements. This does not mean the importer must draw up the passport itself — that typically falls to the manufacturer — but it does mean the importer checks whether the passport exists, whether the QR data carrier works, and whether the contents match the mattress actually being imported. For a company with 10 to 100 employees, this means in practice: someone on the procurement or quality team who opens a passport before each shipment, compares the data against the order specification, and reports any discrepancies. How that check is carried out is detailed on How do I check whether my supplier's data is correct?

Adding own data

In addition to the product data from the manufacturer, information comes in that is specific to the importer: name, registered business name or brand, and contact details. This is not a matter of data being "passed through" — the importer is themselves responsible for ensuring this data reaches the correct place in the passport and stays up to date, even if the company relocates or changes its name.

Keeping and making available records

An importer maintains documentation showing that the mattress meets the requirements, and keeps this available for supervisory authorities. For a small or medium-sized company, this amounts to a file per product line or per shipment: the passport itself, the underlying declarations from the manufacturer, and the correspondence showing what agreements have been made regarding the data. What those agreements are and how they are documented is best settled when drawing up the purchase contract — see How do I document the supply of passport data in my purchasing contract?

Cooperating with customs controls

Article 15 of the ESPR (Regulation (EU) 2024/1781) describes that customs authorities may consult the digital product passport during border checks, linked to the "single window" system for customs. For an importer, this means the shipment may be delayed if the data carrier is not readable, the passport cannot be linked to the correct shipment, or the data is incomplete at the time of import. This is a practical point separate from the question of whether the importer has done something wrong themselves: if the manufacturer outside the EU supplies an incomplete passport, it is the importer who faces this at the border.

Responding if something is not correct

If an importer has reason to believe that a mattress does not meet the requirements, they do not place the product on the market until it is in order, and inform the relevant supervisory authority if there is a risk. This requires an internal agreement on who makes that decision and on what basis — an empty passport, a non-functioning QR code, or data that does not match the physical product are clear triggers in this regard.

Where things go wrong in practice

A few situations come up regularly with companies importing mattresses:

The manufacturer outside the EU supplies no passport data, or incomplete data. Without influence on EU regulations, a manufacturer in a third country often has no intrinsic incentive to prioritise this unless it is contractually agreed. See on this point My supplier does not provide the data — what can I do?
It is assumed that "the supplier will take care of it" is sufficient. The obligations of the importer under Article 29 are separate from what the manufacturer does or does not do. Even with a complete passport from the manufacturer, the importer remains themselves responsible for the check and for adding their own data.
Data on foam, springs and cover come from different parties outside the EU and are not coordinated with each other. For mattresses consisting of multiple components with different origins, a passport is only created once these data come together. How this is being addressed is set out on how do I combine data from different foam and spring suppliers in one passport
When changing manufacturer or supplier, the link with the existing passport is lost. An importer switching to a different manufacturer outside the EU for the same model must be aware that a passport does not automatically transfer. This is detailed on does the product passport remain accurate if I switch to a different mattress material supplier
Sensitive formulation or composition data are not protected before being shared. Manufacturers outside the EU are sometimes reluctant to share composition data without a confidentiality agreement. See can I arrange an NDA with my supplier regarding the data for the passport

What you can record

An overview of which data the manufacturer outside the EU supplies, and which data the importer adds itself — see also Which data must I request from my mattress supplier?
Contractual arrangements with the manufacturer regarding delivery, updating and accuracy of the passport data, including a point in time at which this is checked prior to shipment
An internal file per product line or shipment with the passport, the underlying declarations and correspondence on this
An established procedure for checking the passport and QR data carrier before arrival at the border, including who does this and what happens in case of discrepancies
A documented procedure for the case where a passport is missing, unreadable, or does not match the product — including who internally decides not to place a shipment on the market

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.