How does the digital product passport work for made-to-measure mattresses?

A custom-made mattress also receives its own passport

A mattress that is custom-made — with a non-standard length, width, core or firmness — will soon receive a digital product passport just like a mattress from the standard line. The passport follows the product as it is actually manufactured and sold, not an average model from the catalogue. This means that the data in the passport — materials, composition, dimensions, maintenance instructions — correspond to the mattress that is on that one customer's bed, even if it is composed slightly differently from the mattresses next to it on the same production line.

Who this applies to, and what it does not

This procedure is intended for mattresses that are placed on the market as a finished product, whether that is a standard size or a made-to-order version. Whether a "custom-made" mattress means a non-standard dimension within an existing product line, or a completely individually assembled mattress, in both cases it is a product that is supplied to a user and thus may fall under the passport obligation once mattresses as a product category are designated. This is different for components that are sold separately, such as a replaceable cover or a topper purchased independently — separate rules may apply to these, which are not addressed here. A one-off prototype that is not sold is also outside the scope outlined here: the passport belongs to a product that reaches the market.

When this comes into effect is not yet fixed

There is no established date on which mattresses will actually fall under the passport obligation. This depends on a delegated act that the European Commission must establish for this product group under the ESPR. According to the Commission's work plan for 2025-2030, that act for mattresses is expected in 2028, but this is a schedule and not a commitment regarding an outcome or timing. Once the act is published and the date is confirmed, it will be stated here. Until then, nothing changes for custom-made mattresses in the existing way of selling and informing customers.

How this works in practice for a manufacturer or seller

Anyone making custom-made mattresses would be wise to start thinking now about how product data per order is recorded, rather than only at model level. A logical sequence: first, for each order, the materials, core structure and dimensions used are registered — these are the data that will form the basis for the passport of that specific unit. Next, a unique identification code is assigned to that mattress, as required by Article 12 of the ESPR, so that the product can be unambiguously distinguished from other mattresses — even if they appear identical. Then the passport itself is compiled and linked to a QR code that is affixed to or with the product; this is the data carrier that makes the information accessible to the customer, the seller or a supervisory authority. It is important that if the composition is modified — for example, a different foam type in a later order — this is fed back to the passport of that specific unit, and not silently incorporated into a passport that has been drawn up for an entire model. For a platform that compiles passports and hosts them for ten years, this means that the source data per mattress — not per model name — must be provided by the manufacturer or importer.

What this is based on: Articles 11 and 12 of the ESPR

Article 12 of Regulation (EU) 2024/1781 stipulates that the digital product passport contains a unique identification code with which the product can be specifically identified. For bespoke mattresses, this means that identification is at the level of the individual product, and it is not sufficient at the level of a model name or type designation when the actual composition differs per specimen. Article 11 describes the technical setup and operation of the passport, including the link between the data carrier and the specific product to which the data relate. Together, these provisions form the basis for the assumption that a bespoke mattress receives its own passport tailored to that specimen, rather than a shared passport for an entire product line.

Manufacturers who already produce bespoke mattresses can benefit most from putting their own product administration in order: recording per order which materials and dimensions have been used, so that those data can be processed in a passport without additional research work as soon as the obligation actually comes into force.

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

Custom-made mattresses — a different length, an adjusted width, a specific hardness combination ordered by a bed specialist or hotel chain — do not fall outside the digital product passport because they do not come from standard production. Article 11 of the ESPR (Regulation (EU) 2024/1781) sets requirements for the technical design and operation of the passport, but makes no exception for small batches or individual orders. For a company that manufactures custom-made products, this amounts to a couple of practical obligations.

Each custom-made unit receives its own identity

Article 12 of the ESPR requires a unique identification code per product. In series production, this is a matter of assigning a code per model or per batch. With custom-made products it is different: a mattress of 210 x 100 cm with a customised core is a different product than the standard size, even if the rest of the structure is identical. For a company with 10 to 100 employees, this means that production administration must be able to indicate which specific version goes with which code, and not only which model name appears on the purchase order. How that code looks in practice and is assigned is described on How do I give each product a unique identification code?

The passport must represent the actual version

A passport that displays the standard specifications of a model line while the customer has ordered a different size or filling does not meet the purpose of Article 11: information that corresponds to the product to which that information belongs. For custom-made production, this means that the data that enters the passport — dimensions, material composition, any deviating hardness class — must be determined per unit or per order, not automatically taken from a model template. This is an extra step in the process that is not necessary for off-the-peg mattresses, and is particularly relevant for companies that produce many variants simultaneously.

The data carrier must remain linked to the correct passport

Because each custom-made unit has its own passport, the QR code on that specific unit must also refer to that passport — not to the passport of the model line it is derived from. In production in small batches, the risk of confusion is greater than on an assembly line with identical products, simply because more variants are in the process at the same time. Which technical route fits this, including the question of whether GS1 Digital Link offers a solution for variable product codes, is explained on What is GS1 Digital Link and do I need it for the digital product passport?

Registration in the European register must be correct per version

Once a product passport is created, a mention in the central register must go with it. With custom-made products, the question is relevant whether each version is registered separately or whether a basic registration is used that is supplemented per order. This question is more pressing for companies that produce new combinations daily than for companies with a fixed assortment. More about what must be in that register can be found on What is the register of digital product passports and what must I enter in it?

Where things go wrong in practice

A few situations recur regularly in custom-made production.

The QR code refers to the passport of the base model. This happens when production labelling is set up at model level rather than at unit level, and the adjustment is not carried through in the link to the passport.

The dimensions in the passport do not match the mattress actually delivered. Especially with orders with small deviations (a few centimetres in length, a slightly different core structure) the error creeps in that the standard specification is adopted without correction.

It is assumed that a QR code can be added later. With custom-made products, the mattress is often produced first and only then finally linked to an order or customer. Whether that subsequent attachment of the data carrier is practical and technical possible depends on the process; see can I apply a QR code later to an already produced mattress

With bulk custom orders for hotel procurement, it is assumed that one passport suffices for the entire order. As soon as there are individual units with their own identification code, a separate passport should as a rule be assigned to each one, not one passport for a hundred beds at a time.

The label with the QR code becomes damaged during transport or assembly at the customer's premises, which with custom orders involving additional packaging and adaptation activities occurs more frequently than with standard products that go directly from the factory to the retail floor. What can be done about this is set out on what should I do if the label with the QR code comes loose or wears out

What you can record

A working method in which a unique identification code is generated for each order with deviating specifications, separate from the model code of the standard line.
A fixed moment in the production process at which the passport data are established on the basis of the actual order specification, not on the basis of the model template.
Agreements with the party delivering or assembling the mattress concerning verification that the QR code is still readable and correctly linked at the moment of delivery.
An overview of which production systems or ERP links are used to translate custom specifications into the passport; see also Can I link the digital product passport to my ERP or inventory system?
A documented procedure for the registration of each unit in the central register, including who is responsible for this during peaks in order volume.
Documentation of the link between order slip, unique identification code and QR code per unit, so that in case of an inspection or complaint it is traceable which passport belongs to which delivered mattress.

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.