do I still need to carry a separate textile label alongside the digital product passport
The passport sits alongside existing labels, not replacing them
No, the digital product passport does not replace the textile label. The textile label — with fibre composition, washing instructions and the like — stems from legislation other than the ESPR (Regulation (EU) 2024/1781) and continues to exist alongside it. The digital product passport is an additional, digital layer with information that is much broader than what fits on a textile label: from material composition and repair options to separation instructions for recycling. Both exist side by side, each with its own purpose and its own legal basis.
Which label this applies to, and which it does not
This question arises particularly with mattresses with a textile covering, which traditionally carry a fibre label showing the composition of the cover fabric. That label remains required as long as the underlying textile legislation requires it, independently of what appears in the digital product passport. The passport itself does not focus on the cover fabric alone, but on the mattress as a whole: foam type, flame retardants, recycled material, service life and more, as described in Articles 5 to 7 of the ESPR (Regulation (EU) 2024/1781) on ecodesign and information requirements. Other mandatory markings — such as CE marking where applicable, or safety warnings — also fall outside the passport and remain a separate obligation in themselves. What the passport does do, then, is bring together and make digitally accessible product information that is now often available only on paper, on the invoice, or not at all. What it does not do is make existing physical labels redundant.
No fixed date yet, but a clear direction
There is no definitive date yet on which the digital product passport will become mandatory for mattresses. The ESPR (Regulation (EU) 2024/1781) is the framework regulation; the specific obligation for a product category such as mattresses is established through a delegated act that is set for each product category. For mattresses, that act has not yet been published. Until then, nothing changes in the existing label requirements: the textile label and other mandatory markings continue to apply as they do now, regardless of progress on the digital product passport. As soon as a published delegated act is available with a concrete entry into force date for mattresses, it will be stated here.
What this means for the approach
In practice, the sequence is mainly a matter of not changing anything: the textile label continues in the way it is currently applied, and nothing needs to change about it because of the digital product passport. Attention can therefore be focused entirely on the passport itself, as a separate process. A logical first step in this regard is to get a picture of what data will be included in the product passport for mattresses, because that is a different and broader set than what appears on a textile label. Think of the foam type and density of the core material, the proportion of recycled material, and information that is often not systematically recorded anywhere today.
A second point to address early is the substantiation of technical claims. For those already thinking about how foam type and density are recorded in the product passport, or about the way in which the expected service life of a mattress is substantiated, it is advisable to know that this data must be measured or substantiated according to a documented method — that is different from free text on a label. Matters such as flame retardants and allergens used also get their own place in the passport, separate from any current entries on a label or in product information.
Those concerned that commercially sensitive information might become public in this way can look into that separately: not all data in the passport is visible to everyone, and there is a distinction between what is publicly accessible and what is intended only for certain parties in the supply chain.
The legal basis: article 10 and articles 5 to 7 of the ESPR
The obligation to provide a digital product passport is set out in article 10 of the ESPR (Regulation (EU) 2024/1781), which describes the requirements that the passport must meet. The substantive information requirements — which product characteristics must be recorded — follow from articles 5 to 7 of the same regulation, which govern the ecodesign requirements and the performance and information requirements. None of these articles withdraw or replace an existing label, such as the textile label; it is a supplementary mandatory instrument that is being introduced through a separate legislative procedure (textile regulation versus the ESPR). Both regulations have their own legal basis and their own scope, and they will continue to exist alongside each other until the legislator decides otherwise.
What to do now
For now, it is practical to continue to use the textile label as is already being done, and in parallel to build up an understanding of which mattress data will need to be included in the digital product passport — so that the administration for it is in place when the delegated act for mattresses is published.
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 product passport and the textile label are two separate obligations
The digital product passport prescribed by the ESPR (Regulation (EU) 2024/1781) is not a replacement for existing textile labelling obligations. Article 10 of the ESPR describes what must be included in the passport and how it must be made accessible, but says nothing about withdrawing other labelling obligations. For a mattress manufacturer, this means in practice that introducing a QR code on the mattress does not automatically make the existing label on the ticking redundant. A company with 10 to 100 employees must reckon with the possibility that both tracks — the passport and any labelling obligations on fibre composition — may continue to exist side by side, unless the regulator explicitly decides otherwise.
The content of the passport is broader than a textile label
Articles 5 to 7 of the ESPR (Regulation (EU) 2024/1781) describe the ecodesign requirements and information requirements that form the basis for what will be included in the passport. This covers sustainability, reusability, repairability, material composition and similar product characteristics — a broader package than the fibre composition shown on a textile label. For practical purposes, this means that a manufacturer who simply transfers his textile label data to the passport will probably not meet the full information obligation. Which data is precisely required is described on the page about what data will be included in the product passport for mattresses.
The final delegated act still needs to make this concrete
For mattresses, it has not yet been established via which delegated act the precise product requirements and information requirements will be set out. This means that a definitive answer to the question of whether the textile label will continue to exist alongside the passport cannot yet be given. What is certain: the ESPR itself does not provide for the withdrawal of the textile regulation or similar labelling rules. A company can therefore reasonably assume that preparing for the passport is a supplement to existing obligations, not a replacement for them — until the final regulations indicate otherwise.
The information must be consistent between label and passport
If both obligations remain in place side by side, a practical challenge arises: the data on the textile label and the data in the digital passport must correspond with each other. For a company that produces mattresses with different upholstery fabrics, this means that the fibre composition shown on the ticking must be traceable in the passport and must not differ due to, for example, an outdated specification or a different supplier of upholstery fabric. This also raises the question of how often data is updated, described on the page about how current the data in the product passport must be.
Where things go wrong in practice
Assumption that the QR code replaces the label. A manufacturer decides to remove the textile label from the production line because the mattress already has a QR code. As long as the legislation does not formally revoke the textile label, this creates a gap: the legally required label information is then no longer found anywhere on the product itself.
Different data on label and in passport. With an assortment of multiple upholstery variants, the textile label is adapted per batch, but the passport is not updated accordingly. The customer scans the QR code and sees a different fibre composition than appears on the label.
Textile label is regarded as sufficient passport content. An importer thinks that taking over the label data (fibre composition, washing instructions) is sufficient for the passport. However, the information requirements from the ESPR go further, including topics such as disassembly and repair — see the page about the disassembly instructions of a mattress.
Unclear responsibility for which label. In private label production, the manufacturer prints the textile label and the client holds the passport, without agreement on who supplies and checks which data. This leads to delays or contradictory information when the passport is being compiled.
No attention to allergy or maintenance information on either medium. Some textile labels contain washing instructions or maintenance advice. If that information does not consistently appear in the passport, confusion arises for the end user. This concerns the topics covered on the pages about repair and maintenance instructions en allergy and health information.
What you can record
- An overview of which label obligations currently already appear on the mattress or packaging (textile label, washing instructions, filling material), separate from the future passport.
- An internal agreement on who manages the data on the textile label and who enters the data in the digital passport, so that one person or team is responsible for consistency between the two.
- A comparison document in which, for each product variant, the fibre composition, material information and maintenance instructions shown on the label are recorded, so that this can easily be checked against the passport data.
- A procedure to update both information sources at the same time when a supplier of upholstery fabric or filling material changes.
- A note in the product file about the date when the final delegated act for mattresses is published, so that it is clear from what point any changes in label obligations will apply.
- Documentation of the source of each piece of data (supplier declaration, test report, internal measurement), which also aligns with the substantiation required for the page about how the values for the passport are measured.
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.