Does the product passport also apply to mattresses supplied to hotels?
Yes, mattresses supplied to hotels are also covered
The digital product passport for mattresses is linked to the product, not to the buyer. A mattress supplied as hotel procurement is the same product under the ESPR (Regulation (EU) 2024/1781) as a mattress sold to a private individual in a bed specialist shop. The regulation makes no distinction between a business buyer and a consumer: once a mattress is placed on the EU market, the rules apply to that product, regardless of who ultimately uses it. For hotel procurement, this means that in practice there is no separate, lighter route because the mattresses are "intended for the business market".
Who this applies to, and where the nuance lies
The point of reference is not the destination of the mattress, but the "placing on the market" of it: making it available for the first time on the EU market, in the course of a commercial activity. This is typically done by the manufacturer or the importer. A hotel that purchases mattresses via a regular supplier or wholesaler in the EU receives a product in that chain for which the passport obligation already lies with the manufacturer or importer — the hotel itself does not then need to compile anything. The situation is different when a hotel (chain) itself directly imports mattresses from outside the EU, for example for a new construction project with a supplier outside the Union. In that case, the hotel may be regarded as an importer for that specific delivery, with the obligations that entails. Shops, wholesalers and other intermediaries that resell mattresses without importing themselves fall under the provisions for distributors and traders.
What is not covered is the question of how the mattress is subsequently used or rented. Whether a mattress is in a hotel room, in a hospital, or at home, it does not change the passport obligation that arose from placing it on the market. Nor does it matter for the scope of Article 1 whether the mattress is ordered in bulk or sold individually — it is a question of the fact that the product is offered.
When this comes into effect is not yet fixed
There is no fixed date yet for when the passport obligation for mattresses comes into force. The ESPR itself is the framework; per product group, the European Commission sets out the concrete requirements in a delegated act. For mattresses, this is on the ESPR work plan 2025-2030, with a delegated act expected in 2028. As long as that act does not exist, there are no concrete passport requirements for mattresses — the obligation only arises with the publication of that act, and only after that is there also a transition period until the date on which compliance becomes mandatory. Until then, there is no legal obligation for manufacturers, importers and hotel procurement to maintain a mattress passport. Once the delegated act is published, the date will be added here.
What this means for hotel procurement, step by step
For hotel buyers now purchasing mattresses, it is practical to first check through which channel the mattresses arrive: if purchasing via a supplier or wholesaler within the EU, the future passport obligation rests with that party, and it is mainly important to put this on the agenda with the supplier once the regulations become concrete. For direct imports from outside the EU, it is worthwhile to already inventory which party in the chain would qualify as the importer, so that this does not come as a surprise when the delegated act is published. For current and future procurement processes, it is also practical to include a question in requests for quotations and contracts about the presence of a digital product passport, so that suppliers can anticipate this in time. Finally, for hotel chains with a long mattress replacement cycle (often multi-year), it is useful to know now that a passport, once mandatory, must remain accessible throughout the product's period of use — this is relevant for those who keep mattresses in operation for years.
Where this follows from
The fact that the ESPR makes no distinction between business and private purchasers follows from Article 1 of the regulation, which determines the subject matter and scope on the basis of placing products on the market, not on the basis of the purchaser. The division of obligations between manufacturers, importers, distributors and dealers — relevant to the question of which role each party in the hotel chain fulfils — is set out in Articles 30 and 31 of the same regulation.
Hotel buyers who are already active in procurement can best enquire with their own supplier about who in the chain acts as manufacturer or importer, and repeat this question once the delegated act for mattresses has been published.
Where this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 1 (subject matter and scope)
- Regulation (EU) 2024/1781 (ESPR), Articles 30 and 31 (obligations of distributors and traders)
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 mattress that ends up in a hotel room is, for the ESPR, simply a mattress being placed on the market. Article 1 of the ESPR (Regulation (EU) 2024/1781) makes no distinction between a mattress sold to a consumer and a mattress supplied to a business customer such as a hotel. The scope is linked to the product itself and the product group, not to who the buyer is. Once the delegated act for mattresses is in place and mattresses are designated as a product group, the digital product passport requirement therefore applies in principle also to supplies to hotels, care institutions, rental companies and other business customers. What exactly falls under the product group is described on which products in the mattress industry fall under the ESPR.
The manufacturer or importer remains responsible for the passport
Whoever produces or imports the mattress compiles the passport and ensures that it is present at the moment the product is placed on the market. This does not change because the buyer is a hotel chain instead of an online shop or a specialist bed retailer. For a company with 10 to 100 employees, this means that the existing route for compiling and providing passport data is also applied to mattresses made specifically for the hospitality market, including any variants with non-standard dimensions, firmness or flame-retardant covers often made specifically for hotels.
Distributors and traders check, they do not compile
Articles 30 and 31 of the ESPR describe the role of distributors and traders: they verify whether the passport is present before the product is offered, but they do not compile the passport themselves. For a supplier who resells mattresses to hotels without being a manufacturer, this means primarily a checking task: is there a passport, is the QR code readable, and is the product not offered further without a passport. Anyone in doubt about whether their role in the chain is that of manufacturer, importer or distributor will find the basic principles in what the ESPR changes for the mattress industry.
Large volumes and custom-made products for hotels require the same level of care
Hotel purchasing often works with large, recurring orders of a single mattress model, sometimes in a version that is not in the regular consumer range. In practice, this means that each model — even a version made only for the business market — gets its own passport that matches that specific model. A passport compiled for the consumer version of a mattress does not automatically cover a hotel version with a different core, firmness or fire safety requirements.
Where things go wrong in practice
A supplier assumes that business sales fall outside the scheme, because there is an impression that the passport is only intended for consumer products. This assumption is not tenable: the scope of Article 1 of the ESPR does not make that distinction.
A manufacturer makes a customised version of an existing mattress model for a hotel chain — a different firmness or an extra flame-retardant layer — and supplies it under the passport of the standard model, whilst the material composition differs.
An importer supplies directly to a hotel in another EU country and assumes that the rules of the country of destination are decisive, whereas the ESPR is specifically designed to operate in the same way throughout the EU.
An intermediary who purchases mattresses from a manufacturer outside the EU and resells them to hotel chains sees itself as a "mere supplier" and does not assume that the obligations for importers apply to its role.
A hotel operator orders mattresses directly from a factory outside the EU, outside the usual European distribution channels, with no one in the chain feeling responsible for having the passport compiled.
What you can record
- An overview of all mattress models and variants produced specifically for business customers such as hotels, including deviations in material, firmness or fire safety design compared to the consumer model.
- Documented agreements with hotel chains and purchasing organisations about which role each party fulfils in the chain — manufacturer, importer, distributor — so that it is clear who compiles the product passport and who merely verifies it.
- An internal procedure indicating that a new product passport is requested as soon as a mattress model is adapted for a specific business order, even if it is a minor modification.
- Documentation of the data supplied for the product passport of each model, so that during an inspection it is clear which version belongs to which product passport; the exact data this comprises is described on what data will be included in the mattress product passport.
- A fixed working method for the QR data carrier for large hotel orders, so that each delivered mattress — even with orders of hundreds of units for one hotel — is provided with the correct, legible code.
- For companies uncertain whether their scale has a bearing on what is expected: a look at does the product passport also apply to small businesses provides initial guidance.
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.