How does the QR code for the digital product passport get on my mattresses?

A physical data carrier on the mattress, linked to the online product passport

The QR code is placed on the mattress as a physical data carrier: a label, hang tag, sewn-in label or sticker on the packaging that points to the digital product passport available online. Matrapas.eu compiles that passport as soon as the manufacturer or importer has submitted the product data, and then returns the QR code as a file. The placement of that code on the physical mattress — printing, sewing, sticking — is then carried out in the production or packaging line of the manufacturer itself, or via the party that handles it for him. The QR code itself contains no product data; it merely points to the location where the passport is held, so that a change in the data later does not mean the label has to be reprinted.

Article 11 of the ESPR (Regulation (EU) 2024/1781) specifies that the data carrier must be physically present on the product, on the packaging or in the supplied documentation, and that it must remain legible and accessible during the relevant period. For a mattress, a sewn-in label or a sturdy hang tag is the obvious choice, given the long service life and the stress to which a mattress is subject — but the exact form, location and material requirements for mattresses will only be laid down in the delegated act for this product group.

Who this applies to, and where the boundary lies

This obligation is intended for those who place mattresses on the EU market as a manufacturer or importer, at the moment the delegated act for mattresses enters into force. It does not apply to mattresses that have already been sold or are in stock with the trader before that date — the ESPR generally does not apply retroactively to products already placed on the market, although the exact transitional provisions for mattresses are not yet established because the delegated act does not yet exist.

It is also important to distinguish between the QR code as a data carrier (Article 11) and the label itself (Articles 16 and 17). A label may contain additional, directly visible information that is separate from the passport, and the ESPR prohibits labels or markings that so resemble a mandatory label that they could cause confusion (Article 17). This is relevant for those who wish to place their own quality mark or QR code for other purposes on their own label: those two must be clearly distinguishable to the user from the data carrier that points to the official passport.

No fixed date yet, but a fixed framework

When the QR code obligation for mattresses comes into effect is not yet established. According to the European Commission's work plan for 2025-2030, the delegated act for mattresses is expected around 2028, but this is a planning date from a work plan and not a legally established entry date. Once the delegated act is published, the specific date and any transitional period will be shown here.

Until then, the general framework of Article 11 is established: how a digital product passport must technically work, including the requirement that a physical data carrier must be present that refers to the passport. Manufacturers who wish to prepare now can use that framework to think ahead about where and how a QR code would best fit on a mattress, without there being a legal obligation to do so yet.

How this is handled in practice

The sequence in which this is typically handled is as follows. First, the product data that will eventually have to appear in the passport is gathered — material composition, origin, maintenance instructions and whatever else the delegated act requires. That data goes to matrapas.eu, which processes it into a digital product passport and hosts it for ten years. Matrapas.eu then supplies the QR code as a file: an image that can be used on a label, hang tag or packaging.

Next, it is up to the manufacturer to determine how that code physically ends up on the mattress. For a mattress, a solution that outlasts the product's useful life is obvious: a sewn-in label, for example, lasts longer than a simple sticker that can come loose. Anyone exporting a mattress or supplying it through an intermediary is well advised to agree in advance who is responsible for applying the label — the manufacturer, the importer, or the party handling the final packaging. Finally, it is practical to test the QR code for readability under normal retail conditions, and to check that it cannot be confused with other labels or quality marks already on the product.

The legal basis: Article 11, 16 and 17 of the ESPR

That the QR code as a physical data carrier must be on the product, packaging or documentation, and must remain readable during the relevant period, follows from Article 11 of the ESPR (Regulation (EU) 2024/1781) on the technical design and operation of the digital product passport. The rules on labels in general are in Article 16, and the prohibition on labels that could be confused with a mandatory label is in Article 17. The specific requirements for mattresses — shape, material, location on the product — only follow from the delegated act that the Commission draws up for this product group.

What to do now

Anyone currently manufacturing or importing mattresses can do the most by putting their own product data in order and thinking about a physical label solution that is practically feasible in their own production line. Once the delegated act for mattresses is published, this page will be updated with the exact date, the form requirements and any transition period.