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what should I answer if a customer in the store asks about the product passport

Explain what the passport is and where it is located

A shop assistant can best explain calmly that the product passport is a digital document with information about the mattress — materials, composition, and data relating to repair or recycling — and that this passport can be accessed via a QR code attached to or placed near the mattress. That is the whole answer in essence: no complicated legal story, but a reference to a QR code that leads to a page with product information. The customer can scan that QR code with a phone and then arrives at a page that the manufacturer or importer has had compiled, with the data that applies to that specific mattress.

For which customer question this works, and when it does not

This explanation is intended for the moment when a customer in the shop has seen something about the product passport and asks what exactly it is or where it can be found on this mattress. For that question, the explanation above is sufficient: it concerns an information source, linked to a specific product, with fixed access via a data carrier such as a QR code — this follows from Article 11 of the ESPR (Regulation (EU) 2024/1781), which describes the technical operation of the passport. Where this explanation is not intended: a question about whether the passport is now mandatory for the specific mattress the customer is holding. That is a different question, with a different answer, and the answer to that depends on the product group-specific decision that still needs to be made for mattresses. Anyone wondering whether that obligation already applies to the mattresses in their own shop will find a more detailed explanation at does the digital product passport apply to my mattresses. A question about warranty, returns or sleep trial is also a different question from the question about the passport itself — these two subjects sometimes run together in practice, but have nothing to do with each other.

The obligation is not yet fixed; the explanation is

There is no fixed date yet when the product passport becomes mandatory for mattresses. The ESPR itself as a framework is already in force, but the product group-specific rules — which mattresses exactly are covered, which data must be included and from when — follow from a delegated act that still needs to be published. Article 18 of the ESPR describes how the European Commission prioritizes and plans product groups, and mattresses are on that schedule, but the act itself is not yet there. Until that act is published, there is no legal obligation for a product passport for mattresses. This does not mean that a shop assistant must be left with an empty answer: the explanation about what a passport contains and how it works can be given now, even though the obligation is not yet there. Anyone who wants to know what is already worthwhile to do in the meantime while the rules are not yet final will find that at what you can already do while the rules are not yet definitive.

How staff can best conduct this conversation

In practice, it works well to answer the question in three steps. First: confirm that the product passport is a digital information sheet about the mattress, with data on materials and provenance, intended to provide more insight into what a mattress exactly is. Then: explain how the customer can access it, namely via a QR code that leads to the passport page — if one already exists for the mattress in question. And lastly, only when the customer specifically asks: honestly say that the obligation for mattresses is not yet definitive, without naming a date that is not yet fixed. A staff member who does not have this at hand can simply say that more information will follow or that the manufacturer is the source of this — that is a fine answer, and better than guessing. Shops that want to prepare this conversation structurally can train staff on it using a few fixed sentences; how this can be approached is set out at how do I inform my shop staff about the digital product passport for mattresses. For shops that still need to work out exactly where to start with the passport itself, there is an overview at how do I approach the digital product passport for mattresses step by step.

The basis: Article 10 and Article 38 of the ESPR

The content and accessibility of the passport are determined by Article 10 of the ESPR (Regulation (EU) 2024/1781), which specifies what types of information a digital product passport must be able to contain and for whom that information must be accessible — including for the consumer. Article 11 governs the technical design, including the data carrier such as the QR code through which a customer can access the passport. Article 38 addresses the obligations of actors in the supply chain, including the retailer, and stipulates among other things that these parties must keep the data carrier visible and accessible to the customer at the point of sale. These articles thus establish what must happen once the obligation takes effect — but when that concretely becomes mandatory for mattresses follows, as stated, from a product group-specific delegated act that does not yet exist.

A shop that wishes to be able to have this conversation now would do well to have a few short, factual sentences ready for staff, so that no one has to guess at a date or an obligation that has not yet been determined.

What you concretely must do

What is expected of you

A customer who asks for the product passport in the shop is essentially asking a question about access to information. What this practically entails can be broken down into a few separate obligations.

Making access to the passport possible

Article 10 of the ESPR (Regulation (EU) 2024/1781) stipulates that the digital product passport must be accessible via a data carrier, such as a QR code, affixed to or attached to the product. For a shop with sales staff, this means that the QR code on the mattress or on the label must be findable, and that someone on the shop floor must know where that code is and what happens when you scan it. For a company with 10 to 100 employees, this is usually not a technical problem — the manufacturer or importer supplies the code — but rather an organisational matter: staff must be able to show and explain that code, even if the mattress is on a shelf without packaging.

Explaining what there is to see

Article 11 of the ESPR (Regulation (EU) 2024/1781) concerns the technical design and operation of the passport, including the requirement that the data be readable and accessible to the end user. This does not mean that a sales assistant must know the entire regulation, but it does mean that someone in the shop must know what a customer sees after scanning: materials, repair and recycling information, and where it comes from. A customer who asks "what is in there then" deserves an answer that goes beyond "I don't know".

Knowing when the passport is or is not yet required

Article 18 of the ESPR (Regulation (EU) 2024/1781) governs the prioritisation and scheduling of product groups for which requirements will apply. For mattresses, it has not yet been determined when the obligation will precisely take effect. For a shop it is practically relevant to know whether a mattress already falls under the scheme, will fall under it, or whether nothing changes for now — that distinction determines whether a QR code should be present. Those who still want to work this out for their own situation will find the background in when the product passport becomes mandatory for mattresses.

Knowing who is responsible for what in the chain

Article 38 of the ESPR (Regulation (EU) 2024/1781) describes the obligations of actors in the supply chain, including distributors and sellers. A shop is normally not the compiler of the passport — that is the work of manufacturer or importer — but rather the party that conveys the information to the end customer. For sales staff it is helpful to be able to say: "we have received this information from the manufacturer, and they are responsible for the content." That is not an evasive answer, it is an accurate description of the division of roles.

Where things go wrong in practice

A few situations recur regularly for shops that face this question.

A seller doesn't know that there is a QR code on the mattress because it has been placed on a label underneath the mattress and nobody has ever looked for it. The customer asks for the passport, and the answer is "we don't have that" — while it's actually there, just not found.

A customer scans the code themselves with their phone and ends up on a page that doesn't load, is incorrect, or refers to an old version. Nobody in the shop knows who should be called about this: the manufacturer, the webshop builder, or their own ICT contact person.

A seller gives substantive warranty regarding durability or material origin that is not stated in the passport, in order to satisfy the customer. That is a statement that doesn't come from the source data and cannot be substantiated afterwards.

A mattress from older stock has no passport, while a comparable new model does. The customer wonders why one product has a code and the other doesn't, and the staff don't have an explanation ready about that transition. Background on that situation is stated in what to do with stock already in place when the rules come into effect.

A customer asks about the passport for a mattress that has been returned after trial sleeping and is being resold. No one has considered whether the data carrier and the data still apply to that specific unit, especially if parts have been replaced. This relates to the question addressed on the page about mattresses that are returned after trial sleep.

What you can record

  • A brief answer model for sales staff: what to say when a customer asks about the passport, including what is and is not known at store level.
  • An overview of which models in the store already have a QR code and which do not yet, linked to the delivery date or production date.
  • Contact details of the manufacturer or importer responsible for the content of the passport, so that a question the shop staff cannot answer can be directed somewhere.
  • A brief instruction on where the data carrier is affixed to the product or packaging, per brand or supplier.
  • A note on return or trial mattresses about whether the data carrier and information still correspond to the product that has been returned.
  • A training moment for new staff, so that the explanation does not depend on who is on the floor that day. Practical setup for this is described on the page about how you inform your shop staff about the digital product passport.

Anyone who prefers to go through these points in a fixed order will find an overview of the steps in how to approach the product passport for mattresses step by step.

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, reviewed by a human on 2026-09-05. Is something not correct? Let us know — corrections are given priority.