What does the digital product passport mean if I sell mattresses via an online marketplace?

What you concretely must do

What is expected of you

Selling a mattress through an online marketplace does not change the question of who must provide the product passport — but it does add an extra party that must verify or facilitate something. The ESPR makes a distinction between the obligations of the seller (who is regarded as a distributor or trader) and those of the marketplace itself.

Obligations if you sell yourself through a marketplace

Whoever offers mattresses on a marketplace — as an extension of their own webshop or as their only sales channel — remains the party who must verify whether a product passport is present for those mattresses, before the mattress is offered. This is the same obligation as when selling via your own website or showroom: articles 30 and 31 of the ESPR (Regulation (EU) 2024/1781) require distributors and traders to verify that the passport is present, and not to offer any product that they know lacks a passport or that is incorrect. For a company with 10 to 100 employees, this means in particular that the passport — or the QR code that refers to it — must be included with every listing that is created, even if that is a time-consuming, repeated action across hundreds of product variants. More information about what this role precisely entails is on what obligations does a distributor or trader of mattresses have?

Obligations if you are the marketplace yourself

Providers of online marketplaces and search engines are assigned their own role under article 35 of the ESPR (Regulation (EU) 2024/1781). This article applies to the party operating the marketplace, not to the individual seller. For a company that runs its own marketplace — even a smaller, specialised marketplace for, for example, bed retailers — this means that structures must be put in place to identify when an offer without a passport appears, and to act on it. This is a different effort from that of a trader: it is not about assessing one mattress, but about a procedure that continues to function with large numbers of listings.

The practical core: knowing who has which role

Most confusion does not arise from the text of the regulation, but from the question of which role each party fulfils in a given sales chain. A company can simultaneously be the manufacturer of its own brand and a trader for mattresses of another brand that it sells alongside on the same marketplace account. Those two roles entail different obligations. For those who cannot work this out, there is an overview on who is responsible for the product passport of mattresses? and, specifically on the question of whether a company acts as an importer as soon as it places products from outside the EU on a marketplace, on am I an importer or manufacturer according to the ESPR?

Where things go wrong in practice

The listing contains no passport reference, although the manufacturer has provided one. This occurs when the product data from the manufacturer arrives separately from the content that goes to the marketplace. The QR code or link is then in a PDF or email, but is not transferred to the product page itself.

One mattress model is placed under multiple listings on different marketplaces, with inconsistent information. With manual entry on each platform, there is a risk that one listing refers to the current passport and another refers to an older version or not at all.

A marketplace seller assumes that "the marketplace will take care of this". The obligation to verify whether a passport is present lies with the seller themselves as soon as they act as a distributor or trader — not with the platform. The platform has its own, different obligation under article 35, which does not automatically assume the verification per product.

With private label sales via a marketplace, it is not recorded who actually provides the passport. A company that has mattresses made under its own brand and sells them via a marketplace is the brand holder in the eyes of the outside world, but the underlying data often comes from the manufacturer. If that agreement is not documented, delays occur when a listing needs to go online and the passport is not yet ready. See on this subject who is responsible for the passport if I have mattresses made under my own brand en, more broadly, I sell mattresses under my own brand — what obligations do I have?

Changes in the assortment are not implemented across all marketplace accounts. A mattress that changes filling can receive an updated passport in the webshop, while the listing on a marketplace — with its own product code and its own content management — still refers to the old version. What a change in composition means for the passport is on do I need to update the product passport if I change the foam or filling

What you can record

• An overview per marketplace account of which mattress models are listed, with the associated passport link or QR code, so that verification does not have to be done manually per listing.
• A fixed procedure for creating new listings, in which adding the passport reference is a mandatory step before publication — not a step that is "updated" afterwards.
• An agreement with the manufacturer or supplier about when passport data will be provided, especially when multiple marketplaces are being supplied simultaneously from the same stock.
• For private label: a written agreement on who compiles and updates the passport, and how changes are communicated to the party managing the listings.
• A log of when a listing was amended following a change in the product, so that it can be demonstrated that the marketplace version was updated at the same time as other sales channels.
• If applicable: contact with the marketplace itself about how it fulfils article 35 of the ESPR (Regulation (EU) 2024/1781), and what data it requires from sellers in order to do so.

For the broader question of what exactly a product passport is and which mattresses fall within its scope, the what is a digital product passport for mattresses? en does the digital product passport apply to my mattresses? provides a good starting point.