does a mattress topper or cover also need its own product passport

No separate passport yet for toppers and covers

At the moment, there is no regulation that requires a mattress topper or a cover to have its own digital product passport. The ESPR (Regulation (EU) 2024/1781) is a framework regulation: article 1 determines that the regulation itself does not introduce a product passport for mattresses or for toppers and covers, but it creates the framework within which this is developed separately for each product group. Which products will actually receive a passport and from when will only be determined once the European Commission has published a delegated act for that product group. For mattresses, that process is in preparation; for toppers and covers as a separate product group, there is currently no indication that work has already begun on this.

What does and does not fall under "mattress"

The distinction between what does and does not count depends on how the product is placed on the market. A mattress sold with a non-removable cover is one product: the cover forms part of that mattress and therefore does not receive a separate passport. A mattress topper sold separately as its own item — with its own packaging, its own article number, its own point of sale — is in practice a different product from the mattress on which it lies. Whether such a topper will fall under its own obligation in the future depends on whether the future delegated act explicitly mentions toppers as part of the product group "mattresses" or treats them as a separate category. The same applies to loose covers sold as replacement articles or accessories: these currently fall under nothing, and nothing in the ESPR suggests that this will change in the short term. Anyone who wants to know whether the mattress itself already falls within the scope will find the basis for this in which products in the mattress industry fall under the ESPR and in the check of whether the digital product passport already applies to the company's own mattresses.

No date for toppers and covers, nor a date for mattresses either

There is no deadline that can be given for a passport obligation for toppers and covers, because that obligation does not yet exist and there is no delegated act in preparation that specifically points to it. For mattresses themselves, it is different: there is a process running within the Commission's work plan, with a delegated act on the schedule, but the exact date is not yet fixed. As soon as that act is published, the date will be posted here. Until then, no passport obligation applies to mattresses, and certainly not to toppers and covers. More about how that process fits together can be found at when the product passport becomes mandatory for mattresses and at the explanation of what a delegated act precisely is.

What this means for the company's own assortment choices

For those who want to think ahead now, the first step is simply to determine what is sold as one product. A mattress with a permanently stitched cover is one product, and any future passport obligation would then apply to the mattress as a whole — the cover is part of that, not a separate item to be assessed. A mattress offered together with a loose, replaceable topper actually consists of two products that must be assessed separately once the regulation becomes concrete. The second step is: do not anticipate an obligation that does not yet exist for toppers and covers and for which no concrete proposal exists either. Effort that is now put into the mattress itself — knowing which data will be relevant later, such as material composition and origin — is better spent than setting up a passport process for a topper for which no legal basis yet exists. Anyone wondering what data that might be in future can find an overview at which data goes into the passport of mattresses. Anyone selling a box spring, where mattress, base and sometimes a separate topper together form one whole, would be well advised to look separately at how that composite product is treated; this is elaborated at boxsprings and composite beds.

The basis: article 1, article 2 and article 12 of the ESPR

That there is currently no passport obligation for toppers and covers follows from the structure of the ESPR (Regulation (EU) 2024/1781) itself. Article 1 establishes that the regulation provides a framework: it regulates the process by which product groups are designated, but does not itself designate any specific product group. Article 2 provides the definitions that determine what qualifies as a "product" within that framework, and thus also what in a future delegated act could be described as a separate product group — a mattress with a permanently attached cover versus a separately sold topper are, in that system, in principle different cases. Article 12 regulates the unique identifier that is assigned to a product once the passport becomes mandatory; that article too confirms that the linking of a passport to a product only becomes relevant at the moment when a specific regulation has been established for that product group.

Anyone wishing to know now whether their own mattresses will fall under these rules begins with the general test at what a digital product passport for mattresses entails in detail, and subsequently keeps an eye on the publication of the delegated act to see whether toppers and covers are included after all.

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 product passports per product group, and which product groups come up is determined per delegated act. For mattresses, that process awaits that elaboration, as can also be read at what is a delegated act and why does it determine what I must do. For mattress toppers and covers there is as yet no separate elaboration, and that means the question of whether they will receive their own passport cannot at this moment be answered with an article number. What can be said is how the ESPR itself views a "product", and what that means for the way you can already think about topper and cover now.

Determining whether the topper or cover is an independent product

Article 2 of the ESPR (Regulation (EU) 2024/1781) defines a product in broad terms as an object created through production. A mattress topper and a cover are, separate from the mattress, both physical objects that can be produced separately and sold separately. That is relevant for a manufacturer, since a delegated act will subsequently be established per product group, and the question then is whether "mattresses" in that act also includes toppers and covers, or whether these are treated as separate product groups — or are not included at all. For a company of 10 to 100 employees this means practically that the company's own product catalogue is helpful here: which items are sold separately, which only as part of a mattress set, and which are supplied to hotels or specialist retailers as an accessory. That classification can be made now, even without the delegated act being in place.

Making a distinction between "with the mattress" and "sold separately"

A cover that is standard on a mattress and is not separately available is different from a topper that is available as a standalone item in the store or webshop. Article 1 of the ESPR (Regulation (EU) 2024/1781) describes the scope of the regulation as being directed at products placed on the market, and a component that never reaches the market separately is in a different position than an item with its own sales point. For the mattress industry this distinction can be made practically: a list of which components are sold only in combination with the mattress, and which separately have a price, article number and packaging. Anyone seeking more background on this will find at which products in the mattress industry fall under the ESPR an overview of how that scope is structured.

Taking account of the unique identifier for assembled products

Article 12 of the ESPR (Regulation (EU) 2024/1781) describes the unique identification code that is linked to a product once a product passport is mandatory. In the case of a mattress sold as a set with a topper or cover, the question is relevant whether that set is regarded as one product with one code, or whether the topper and mattress would each receive their own code and their own passport. This resembles the question that already exists for box springs, where mattress, base and legs together form one sleep system; the way in which this is assessed is described at does a box spring receive one passport or multiple. For toppers and covers, no comparable elaboration has yet been published, but the system — component of a set versus independently sold article — is the same.

Where things go wrong in practice

A manufacturer assumes that a mattress topper "automatically" falls under the passport of the mattress, because in practice it is often sold together with a mattress. But as soon as that topper is also lying loose in the shop, that is assumption based on habit, not based on an established rule.

An importer of covers assumes that covers are in any case outside the ESPR because it is "just textiles", without looking at what will be included in a delegated act for mattresses — an act that has not yet been published and therefore cannot yet exclude or include covers.

A bed specialist shop communicates to hotel purchasers that "all parts of the bed" will receive a passport, while that term has not yet been established anywhere for toppers and covers. This creates expectations with the customer that cannot be supported by a source, whereas in particular when supplying to the hotel industry, certainty is often required; the status of affairs on this is at the product passport also applies to mattresses supplied to hotels.

A small company postpones the question until "it is clear", and thereby runs the risk that its own product catalogue is not in order when the delegated act does appear. Even for smaller companies, it is already possible to see what is at stake, as can be read at does the product passport also apply to small businesses.

A manufacturer confuses the question "does the topper need its own passport" with the question "which data must be included in the mattress passport", and inserts topper data into the mattress passport without a basis being indicated for this. Which data is expected in a mattress passport is described at what data will be included in the mattress product passport.

What you can record

An overview of your own range in which a distinction is made between components that are sold only together with a mattress, and components that come to market as an independent article.
A list of article numbers for toppers and covers, stating whether these are available separately or exclusively as part of a mattress set.
A file per product line with the technical specifications of the topper and cover separately, so that this data is available as soon as a delegated act for mattresses (and possibly for toppers or covers separately) is published.
A note in your own documentation about the date on which this page was consulted, so that in a later inspection it is clear which version of the regulations was used as the starting point.
A reference to the fuller explanation of what the product passport entails, which can be found at what is a digital product passport for mattresses, for those who wish to share this with colleagues or suppliers.

As soon as the European Commission publishes a delegated act for mattresses, and it includes anything about toppers or covers, this page will be supplemented with what is concretely stated there.

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.