My product needs multiple digital product passports — how does that work together?
Multiple passports can exist side by side
Yes, that is possible: a mattress that consists of multiple separately regulated components may, under the ESPR, be subject to more than one digital product passport. The ESPR operates per product group — for each product group for which a delegated act is adopted, specific requirements apply to the passport (Article 9 of Regulation (EU) 2024/1781). If a product consists of components that each fall under their own delegated act — for example a mattress with an integrated electronic component, or a mattress that is placed on the market as a set with a bed frame — then a separate passport may apply to each of those components. For this reason, the Regulation provides for a system of unique identification codes (Article 12) that is specifically designed to link those passports to one another, so that information does not need to be entered twice and a user can access all relevant data through a single entry point.
For composite products, not for loose documents
This topic concerns products that consist of multiple components, each separately regulated — not a mattress with multiple certificates, marks or national documents alongside it. A fire safety certificate, a warranty document or a quality label is not a "product passport" in the sense of the ESPR and does not need to be linked to a DPP via the identification code in Article 12. This specifically concerns situations where more than one delegated act applies to (parts of) the same physical product. For an ordinary mattress without electronic or otherwise separately regulated components, this issue does not arise in practice: it will be subject to the delegated act that is specifically adopted for mattresses, and nothing else.
No fixed date yet for mattresses
No delegated act for mattresses has yet been published, so the date when a mattress passport becomes mandatory is not yet determined. According to the ESPR work plan 2025-2030, a delegated act for this product group is expected around 2028, but that is a schedule and not a fixed date. As long as that act is not in place, there is no passport obligation for mattresses — nor the question of how that passport would relate to any other passport. That question only becomes concrete once the text of the delegated act is known, because it will specify which data are mandatory and whether there are interfaces with other product groups. Once that date is confirmed, this page will be updated.
How to put this into practice
Those who wish to prepare for this can proceed in the following order. First: check whether the product as placed on the market consists of components that may each fall under their own delegated act — think of a mattress with integrated electronics, or a mattress that is normally sold together with a bed base. Next: for each component, check whether a delegated act has already been published for it, because only then does a concrete obligation arise. If that is the case for more than one component, it is important to agree in advance with the party that compiles the other passport — for example the supplier of the electronic component — on who enters which data and how the unique identification codes of both passports refer to each other. This prevents the same information from being entered twice or, worse, from contradicting each other. Finally: document which information is in which passport, so that a buyer or hotel procurement officer does not have to work out for themselves where to find it.
The basis: Article 9 and 12 ESPR
That a product can be assigned more than one passport follows from the structure of Article 9 of Regulation (EU) 2024/1781: the digital product passport is completed per product category via a delegated act, and that act determines the content and scope for that specific category. When a physical product contains components that fall under a different product category — and thus a different delegated act — the possibility of multiple passports alongside one another arises automatically. Article 12 provides for the unique identification codes — for the product, the market participant and the facility — which serve precisely to enable such separate registrations to be linked to one another and kept traceable.
Anyone developing mattresses with electronic or other separately regulated components now would be well advised to keep this question in mind when setting up their own product data — so that the data can later be easily linked to a second passport as soon as the relevant delegated acts are in place.
Where this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 9 (digital product passport)
- Regulation (EU) 2024/1781 (ESPR), Article 12 (unique identification code)
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 often consists of several components, each of which may fall under its own regulatory framework: the mattress core, the textile, and possibly electronics in the case of adjustable bed bases. If a digital product passport becomes mandatory for those components separately, the question arises of how those passports relate to each other. Article 9 of the ESPR (Regulation (EU) 2024/1781) governs the digital product passport itself, and Article 12 of the ESPR (Regulation (EU) 2024/1781) governs the unique identifier associated with it. These two articles provide a framework, but the precise application for mattresses specifically has not yet been laid down in a delegated act.
One passport per product, not per raw material
The ESPR starts from the product as placed on the market. For a mattress manufacturer, this means: the passport belongs to the mattress as a whole, not to each raw material or component individually. A company of 10 to 100 employees that produces a mattress core itself and sources it from a textile supplier processes the data from that supplier in the passport of the end product. The question "whose passport applies here" thus becomes more a matter of data provision in practice than of multiple separate passports side by side.
Traceability via the unique identifier
Article 12 of the ESPR (Regulation (EU) 2024/1781) describes the unique identifier by which a product and its passport are linked to each other. For a mattress with several components that may each have their own regulation, that code is the reference point for determining which passport belongs to which level of the product. In practice, this means that a company must be able to identify which identifier applies to the end product and, where relevant, how it relates to identifiers for components that already have their own passport elsewhere. More information on the structure of that code is provided on the page on how to give each product a unique identification code.
One data carrier, not a stack of QR codes
For the end user — the consumer, the bed specialist retailer, the hotel buyer — it is undesirable to have to scan multiple QR codes for different passports on a single mattress. The ESPR is based on a system in which the data carrier provides access to the relevant passport information for the product. For a manufacturer, this means that the design of the data carrier on the product is an important consideration once multiple passport obligations coincide. How that data carrier is applied to a mattress is described on the page on how the QR code for the product passport gets onto your mattresses.
Registration with the register
Both Article 9 and Article 12 of the ESPR (Regulation (EU) 2024/1781) are linked to the registration of product passports in a central register. For a product with multiple passport obligations, it is important that the registration makes clear which passport belongs to which part of the product, so that supervisory authorities and market participants are not confused by duplicate or overlapping registrations. What exactly will appear in that register is described on the page on the European register of digital product passports.
Where things go wrong in practice
Duplicate registration of the same component. A manufacturer registers the mattress core both as part of the mattress passport and separately, because a supplier had already created its own passport. This results in two identifiers for what is actually the same physical component.
Unclear responsibility for which level of the product. For a mattress with an integrated electronic component (for example, a sensor), the question may arise as to whether the mattress manufacturer or the supplier of the electronics is responsible for that part of the passport. Without agreement on this, a gap in the data emerges.
One QR code that points to the wrong level. A retailer or hotel buyer scans the code on the label and arrives at passport information for a component, not for the mattress as a whole. This occurs when the data carrier is not consistently set up at the level of the end product.
Data that is not retained when a component changes. If a supplier of textile or filling changes, the passport of the end product is not always updated in that change, even though the composition of the product does change.
Confusion with custom-made mattresses. For a mattress that is custom-assembled from multiple modules, it is not always clear whether each module needs its own passport or whether one passport for the assembled end product is sufficient. How this works for custom-made mattresses is explained on the page about how the product passport works for made-to-measure mattresses.
What you can record
- An overview of which components of the mattress (core, textile, any electronics) may fall under their own passport requirement, and which fall under the passport of the end product.
- Agreements with suppliers about who supplies which part of the passport data, and in which format.
- A fixed assignment of the unique identification code at the level of the end product, including how it relates to any codes of components.
- A description of how the data carrier is set up on the product, so that a scan always leads to the correct level of information.
- A note on the linking with your own ERP or inventory system, especially when components from different suppliers are combined — see the page about linking the product passport to your own system.
- An established procedure for updating passport data when a component or supplier changes.
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.