How do I approach the product passport for mattresses step by step?

What you concretely must do

What is expected of you

A product passport does not come into being all at once. It is a series of steps, and each step produces something that the next step requires. Those who tackle this in the right order prevent data from having to be collected twice or the passport from stalling halfway through because a basic component is missing.

Step 1: determine whether and for which mattresses the passport applies

Before anything is recorded, it must be clear which mattresses in the assortment fall under the upcoming obligation. This is not automatically the same for every model, and the question Does the digital product passport apply to my mattresses? is therefore the first one that must be answered. For a company with 10 to 100 employees, this usually means: going through the assortment per product line, not per individual model, because mattresses within a line often share the same material structure.

Step 2: collect the data the passport needs

Article 10 of the ESPR (Regulation (EU) 2024/1781) describes what kind of information a digital product passport must be able to contain. In practice, this is data about materials, composition and origin that is now often scattered across procurement, production and quality control. For a manufacturer, this means that this data must be brought together per product model; for an importer, it mainly means that this information must be requested from the foreign supplier, and this is often the step that takes the most time.

Step 3: have the data compiled into a passport with a data carrier

Article 9 of the ESPR (Regulation (EU) 2024/1781) stipulates that a product with a digital product passport must have a data carrier, in practice a QR code, that refers to the passport data. This is the moment when collected data is converted into a passport that must remain accessible for ten years and whose QR code will end up on the product or packaging. For a company of this size, this is usually the moment when an external platform is engaged, because hosting passport data itself and keeping it online for ten years is a task that falls outside core activities.

Step 4: prepare personnel and point of sale

A passport that is correctly compiled is still not a passport that lands well with the customer. Shop staff will receive questions about the QR code on the mattress, and it is advisable to determine in advance who what should I answer if a customer in the store asks about the product passport knows how to answer. This requires a brief instruction, not an extensive course, and that instruction belongs in the step before launch, not after.

Where things go wrong in practice

Data is not collected until after the QR code has already been ordered. Some companies have the data carrier printed before the underlying data is complete, with the result that the code points to an empty or incomplete passport as soon as the mattress is in the store.

Material data from suppliers arrives too late. For mattresses with multiple layers (core, interlayer, ticking), material data is often held by different suppliers. Those who start with this only after the rest of the passport is ready will get stuck on the longest lead time in the chain.

No distinction is made between existing inventory and new production. Mattresses already in the warehouse when the obligation takes effect require a different approach than models still being produced. This distinction is often forgotten in practice, although it touches on the question What do I do with mattress stock already in place when the rules come into effect?.

Waiting for the date to be fixed before setting anything up. Because the definitive obligation date is not yet fixed, some companies postpone all preparation. This means that everything has to happen in the last few months, while part of the work can already be done now.

Staff is not informed until the day of launch. Sellers will then for the first time receive questions about the passport at the moment the customer is already asking about it, without having had time to establish a line in answering.

What you can record

• An overview per product line of which models fall under the future passport and which do not, including the reason for that classification.
• A list of material data per mattress layer, including who supplies the data (own production, supplier, importer) and when it was received.
• Correspondence with suppliers in which material data has been requested, so that it is demonstrable when and with whom this was assigned.
• A planning that links steps 1 through 4 to a timeline, even though the definitive obligation date is not yet fixed; see also When will the product passport become mandatory for mattresses? for the current status.
• A brief instruction for store staff about the QR code and the passport, including a few frequently asked customer questions and the corresponding answers.
• An overview of actions already taken, even without definitive regulations; the page What can I do now while the rules are not yet final? provides a number of starting points for this.
• A cost estimate of the process, from data collection to hosting of the passport, whereby What does a product passport for mattresses cost? can serve as a starting point for the budget.

Those who record these documents do not need to reconstruct when which choice was made during an inspection or during an internal handover. This is not only helpful during supervision, it also saves hours of work once a colleague takes over the process or a new product model needs to be handled in the same way.