must the product passport be available in multiple languages
The ESPR does not yet prescribe a fixed language
The ESPR itself does not require a specific language for the data in the digital product passport. Article 10 of Regulation (EU) 2024/1781 (ESPR) sets out the requirements that the passport must meet — that it must be accessible, legible and reliable — but a list of mandatory languages is not included there. The language requirements for a product category such as mattresses will be set out in the delegated act that is being drawn up specifically for mattresses, on the basis of the requirements in Articles 5 to 7 of the ESPR. Until that act is in place, there is no legally established answer to the question of whether a mattress passport must be in one language, multiple languages, or the language of the country of sale.
For whom this is relevant, and for whom it is not
This uncertainty is particularly relevant for manufacturers and importers who sell mattresses in multiple EU countries, and for bed specialty retailers and hotel procurement who offer products from different countries of origin. For a purely national market, the question is less pressing, although it remains unclear whether the final regulation will require a specific language. What does not fall under this: the language of package inserts, packaging text or the textile label that exists separately from the digital passport — these are other obligations, with possibly their own language rules. Anyone wondering whether such a label will continue to exist alongside the passport can read more about this at do I still need to carry a separate textile label alongside the digital product passport. The question of which data must be in the passport anyway, regardless of the language in which they are presented, is a separate matter — see what data will be included in the mattress product passport.
No confirmed date yet, and what applies in the meantime
There is no final date yet for the mattresses product category. According to the ESPR work plan 2025-2030, the delegated act for mattresses is expected in 2028; this date is not fixed and may be postponed. Once that act is published, the actual date will be stated here. Until then, there is no legal requirement for mattresses to have a digital product passport, and therefore no legal language requirement for it either. Manufacturers and importers who are already collecting and structuring data are doing so in anticipation of an obligation whose precise content — including language choice — has yet to be determined.
What a business can do now with this uncertainty
The practical sequence is as follows. First: data that must be collected anyway — material composition, foam type, flame retardants, origin — are most conveniently recorded in a source language that is easy to manage internally, often the language in which the manufacturer itself operates. For the underlying technical recording, such as how do I record foam type and density in the product passport whether which flame retardants must I report in the product passport, the language choice is at this point secondary to the completeness and accuracy of the data itself. Second: when selling in multiple countries, it is prudent to account for the possibility that the final regulation will require translation into the language of the country of sale — this is a common pattern in other EU consumer legislation, although this has not yet been confirmed for the mattress passport. Third: a platform that hosts the passport and provides the QR data carrier can technically prepare multilingual display in advance, so that a later language requirement does not require a system rebuild but is a matter of translation and linking. Once data has been structured and recorded, a language change only requires translation — not rebuilding the underlying dataset.
What this rests on: Article 10 and Articles 5 to 7
The basis for this is laid down in Article 10 of Regulation (EU) 2024/1781 (ESPR), which describes the general requirements for the digital product passport, and in Articles 5 to 7 of the same regulation, which establish the procedure by which product group-specific requirements — including any language requirements — are to be filled in via delegated acts. For mattresses, that specific act does not yet exist, and therefore the legal basis for a concrete language obligation is currently absent. This is a deliberate design of the ESPR: the framework regulation governs the structure, the product group-specific act governs the details.
What to do now
The language of the passport data is not yet legally established for mattresses, so it is prudent to put the data collection itself in order — with an eye to completeness, currency and a structure that can easily be translated later — rather than waiting for the final language rule. Anyone who wants to know in advance what information must be included in the passport, how often it must be updated, or who will be permitted to access the data, will find that elsewhere in this knowledge base; once the delegated act for mattresses has been published, this page will be supplemented with the actual language requirements.
Where this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 10 (requirements for the digital product passport)
- Regulation (EU) 2024/1781 (ESPR), Articles 5 to 7 (requirements regarding ecodesign, performance and information requirements)
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 governs in Article 10 what must be contained in a digital product passport from a substantive and technical perspective, but it does not contain an explicit list of mandatory languages. This is no accident: the precise language rules for mattresses are to be laid down via the delegated act for this product group, and that act does not yet exist. What is established, however, is the approach set out in Articles 5 to 7 of the ESPR: information requirements are worked out per product group, and language is typically one of the points that is addressed in that development. Until that text is available, you can do a number of things to avoid starting completely from scratch.
Determine which countries the mattress is intended for
A manufacturer or importer who supplies mattresses to customers in multiple Member States would be well advised to inventory now the language regions in which a mattress will be placed. This is not a legal obligation that follows from Article 10, but a preparatory step: other EU consumer information legislation often works on the basis that information is available in the language of the country of sale. It is likely that a similar approach will be reflected in the delegated act for mattresses, although this cannot be said with certainty at present.
Record data independently of source language
Practically, this means for a company of 10 to 100 employees, in particular: record the underlying data in such a way that they can later be easily translated or linked to another language version, without the entire passport structure needing to be overhauled. Think of using standardised codes and units instead of running text alone, especially for components such as foam type and density or the share of recycled material. The more a piece of data consists of a code or figure rather than free text, the less translation work will be required later and the smaller the risk of substantive discrepancies between language versions.
Mark free text fields separately
Some parts of the passport are less suited to coding and call for running text, such as the separation instructions for the recycler or an explanation of the expected lifespan. For a company, it is practical to mark these free texts separately in its own data management system, so that it is clear which fields must be translated in the event of a possible multilingual obligation and which do not need to be (because they consist of codes, figures or standardised terms).
Wait for the delegated act before structural choices are finalised
It is advisable not to definitively anchor translation processes and language choices in software or contracts as long as the delegated act has not been published. A language obligation adopted now may differ from what is ultimately established. This does not mean standing still, but rather: building flexibility into the systems that manage passport data, so that a language can be added or adapted later without having to rebuild the entire passport.
Where things go wrong in practice
A manufacturer translates the marketing text of the mattress, but not the technical data such as flame retardants or the separation instruction, because these are considered "background information". Once a language obligation comes into force, it is precisely this technical information that falls under the obligation and thus comes into play first.
A company supplies a bed specialist retailer in a different language area than its own home country, but supplies the passport only in the language of the country of production. As long as there is no legal language obligation, this is not a violation, but it can lead to confusion with the trading partner about what is exactly in the passport.
An importer adds the translation loosely as a PDF attachment alongside the digital passport, while the QR data carrier continues to refer to the original, single-language dataset. This creates two "truths" that can diverge once either is updated, which raises the question how current the data in the product passport must be.
A company assumes without further justification that English as a source language is always sufficient, because it is standard in its own sector. Without an established rule, this is an assumption, not an established obligation, and that assumption can be overtaken once the delegated act appears.
A manufacturer outsources the translation to an external agency without establishing which version of the data has been translated and when. When the data is subsequently updated, for example following a change in what data will be included in the product passport for mattresses, there is a risk that the translated version lags behind the source language version.
What you can record
- An overview of the countries and language areas in which the mattresses are sold, as a basis for a possible later translation obligation.
- An internal list of which passport fields consist of codes, numbers or standardised units and which consist of free text, so that it is clear where translation work would be needed.
- Agreements with any translation agencies on which version of the data has been translated, including date and version number, so that source language and translation remain linked.
- A procedure for updating translated texts when the source language data changes, linked to the existing process for updating passport data.
- Documentation of the measurement method and source of data in the original language, so that a translation is never the only record of the underlying values — see also how the measurement method for these values is substantiated on the page about the method by which values for the passport are measured.
- A note in your own file that the language obligation has not yet been established, with a reference to the publication date of the delegated act as soon as it is known.
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.