does the product passport remain accurate if I switch to a different mattress material supplier

A supplier change does not automatically make a passport incorrect, but it does make it outdated

The digital product passport continues to exist technically and remains accessible if a manufacturer or importer switches suppliers for mattress material — the QR code continues to work and the page remains online. What does not happen automatically, however, is that the content changes along with it. A passport describes a specific product as it has been composed and placed on the market, with the materials and composition of that moment. If the foam, spring system or filling changes supplier, in many cases the composition of the mattress also changes — and therefore the data that should actually be contained in the passport.

Who this applies to and what matters

This applies to any manufacturer or importer who continues to develop an ongoing model or switches suppliers without considering the mattress itself as a "new model". This is not about the question of whether the passport is legally mandatory — that depends on the delegated act that has yet to be published, see when the product passport becomes mandatory for mattresses. It is about the question of what should happen to the content of an existing passport at the moment when the underlying materials change. This is a different matter than the question of whether the product falls under the scheme, see or whether the digital product passport applies to your mattresses.

What is important is the distinction between two situations. If only the name of the supplier changes but the material itself remains unchanged (same specification, same composition, different factory), then the passport content changes little — the origin of a raw material is something different from the properties of the product. If the material does change — different type of foam, different filling, different fibre composition — then the passport is essentially describing a product that no longer exists as described.

When this becomes relevant: no fixed date yet

There is no established entry into force date yet for the digital product passport for mattresses. The ESPR (Regulation (EU) 2024/1781) is the framework; the specific obligations for mattresses must still be worked out in a delegated act, as explained in what a delegated act is and why it is decisive. Until that act is published, it is not established from when a passport is mandatory, and therefore also not what exact requirements will apply to keeping the content current when materials change. What is already established, however, is the principle from the ESPR itself: a passport must contain the product information relevant to that product, and that information must be reliable. Once the date for mattresses is known, it will be stated here.

What to do with a supplier change, step by step

First clarify exactly what is changing: only the supplier, or also the material specification. This distinction determines whether the passport requires an update or not. Next, request the new data from the new supplier — the same type of information that is needed when a passport is first set up, as described in which data are requested from a mattress supplier. If the material has changed, it is important to have that new data processed in the passport before the mattress with the new composition is sold — not afterwards.

In practice, it is advisable to establish this arrangement in advance for each supplier change, rather than sorting it out afterwards: who supplies which data, in which format, and at which point before delivery. This can be included in the purchase contract, as explained in recording passport data in a purchase contract. For mattresses that consist of multiple components from different sub-suppliers — foam from one party, spring system from another — having an overview of who supplies which component is in any case already a point of attention, see combining data from different suppliers of foam and spring systems. A supplier change is then a moment to recheck that overview instead of simply replacing only the modified component.

Finally, it is good not to blindly adopt the new data. As with the initial setup of a passport, it is worthwhile to verify whether the specified specifications are correct, as described under verifying supplier data for accuracy — precisely during a change is the risk of discrepancies between what is ordered and what is actually delivered greater than in a long-standing, established relationship.

The basis for this: articles 9 and 10 of the ESPR

Article 9 of the ESPR (Regulation (EU) 2024/1781) describes the digital product passport as an information carrier linked to a specific product; article 10 sets out requirements for the content of that passport, including that the information must represent the characteristics of the product in question. Article 39 concerns the test, measurement and calculation methods used to establish product data — relevant once material changes also mean changes in measured properties. Article 40 focuses on preventing circumvention and degradation of performance, which relates to situations where a cheaper supplier may meet the same paper specification but delivers a different practical performance level.

Anyone considering a supplier change at this time would do well to already establish what data the new supplier must provide and by what date, so that the passport — once it becomes mandatory — can be amended without delay at the moment the composition of the mattress changes.

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

A product passport belongs to a mattress, and that mattress consists of a combination of materials: foam, springs, ticking, sometimes a specific coating or treatment. Once one of those components switches suppliers, the composition stated in the passport also changes in principle. The question then is not so much whether that has consequences, but what exactly needs to be re-established and verified.

The passport must reflect the current situation

Article 9 of the ESPR (Regulation (EU) 2024/1781) describes the digital product passport as something that contains information about the product that is relevant to its life cycle. A mattress that comes to market with new material from a different supplier is essentially a different product than the mattress for which the passport was originally compiled — even if the appearance and model remain the same. For a company with 10 to 100 employees, this means that a supplier change is not only a procurement decision, but also a moment at which the passport data must be reassessed.

The requirements for content and timeliness from article 10

Article 10 of the ESPR (Regulation (EU) 2024/1781) describes requirements to which the digital product passport must comply, including the accuracy of the information contained therein. In practice, this means that when the composition of a mattress changes — for example a different type of foam, a different spring structure, or a ticking with a different fibre composition — the data on those components must be updated to remain consistent with what is actually in the product. A passport that still shows the data of the old supplier while the material has changed no longer meets what article 10 requires.

Test and calculation methods may differ by supplier

Article 39 of the ESPR (Regulation (EU) 2024/1781) concerns the testing, measurement and calculation methods used to determine whether a product meets the requirements. Different suppliers of foam or springs may have had their material tested in slightly different ways, or applied different underlying standards. For a medium-sized company, this means that the new supplier does not automatically provide the same substantiation as the previous one — this is something that must be requested and compared separately, and not something that comes automatically with the new invoice.

No deterioration under the radar

Article 40 of the ESPR (Regulation (EU) 2024/1781) concerns the prevention of circumvention and deterioration of performance. That article is relevant at the moment when a supplier change is accompanied by a cheaper or differently composed material that either does or does not meet the same requirements. For a company, this means that a change of supplier cannot simply be treated as "equivalent material, different name" — the properties listed in the passport must match what the new material actually delivers.

Where things go wrong in practice

A number of situations recur regularly in the mattress industry during a supplier change.

The passport is simply not updated because no one in the company has assigned that as a task to procurement. The change of supplier runs through the purchasing department, the adjustment of the passport through a different department or an external platform — and the two processes do not touch each other.

The new supplier provides different data than the previous one: a different type of composition overview, a different test report, or no substantiation at all on the first delivery. This is a moment when it is useful to know which data must I request from my mattress supplier, so that the new supplier provides the same kind of information from the start as the existing passport is based on.

For mattresses where foam and springs come from different parties, when switching one of the two suppliers, it is forgotten that the passport describes the combination of both. To prevent this, you can look at the approach described at how do I combine data from different foam and spring suppliers in one passport — precisely when switching one component, an overview of the rest is needed to see what needs to be adjusted.

It is assumed that "equivalent material" also means equivalent passport data. The new supplier may use a similar foam type, but with a different density, a different fire retardant, or a different testing method according to Article 39. Without that comparison, the passport remains outdated in substance, even if no one notices.

For a supplier from outside the EU, there is moreover an additional layer: the data needed on import sometimes differs from what an EU supplier delivers as standard. This is elaborated further at what does the product passport mean if I import mattresses from outside the European Union.

What you can record

When changing a supplier of mattress material, it is useful to set down a number of things in writing, so that the passport matches what is actually in the mattress:

An overview of which parts of the mattress are supplied by the new supplier, and which remain unchanged from the previous supplier or another party.
The composition data and test reports of the new supplier, compared with what was previously in the passport.
An agreement on the provision of data for future changes, recorded as described at how do I record the delivery of product passport data in my purchase contract — this prevents the next change from coming as a surprise.
A check of the supplied data before the passport is adjusted, according to the approach at how do I check whether my supplier's data are correct.
A date and version indication of when the passport was adjusted, so that afterwards it can be traced which data belongs to which supplier and which period.

Whoever records these points at the time of the switch itself prevents the passport from describing for months a supplier who no longer supplies — and that is precisely the moment when the question "is the passport still accurate" can be answered affirmatively.

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.