When will the product passport become mandatory for mattresses?

No fixed date yet, but a work plan has been announced

No delegated act has yet been published that makes the digital product passport for mattresses mandatory, so there is currently no firm implementation date. What is established, however, is the process by which that date will be set: the Ecodesign for Sustainable Products Regulation (ESPR, Regulation (EU) 2024/1781) is a framework regulation. It introduces the product passport as an instrument, but regulates separately for each product group — via a separate delegated act — whether, when and with what content that obligation will apply. For mattresses, that product-specific act does not yet exist. As soon as it is published, the concrete date will be posted here.

For whom this will apply, and for whom it does not yet

The obligation that is coming is directed at mattresses as a product group within the European Commission's work plan for priority products under the ESPR. Manufacturers and importers who place mattresses on the EU market are the parties for whom this rule will become relevant; bed specialists and hotel procurement will mainly encounter it as a purchaser who must be able to show or pass on a passport, not as the party that has to draw up the passport itself. It is also important to note what is not yet regulated: the ESPR itself does not currently require any mattress to have a product passport. That obligation will only arise with the product-specific delegated act for mattresses, and that does not yet exist. Everything that is now said about mattresses — including on this platform — is therefore preparation for something that has yet to be established, not an explanation of a rule that is already in force.

The date is not yet fixed — but this is known

To be clear: there is no official date on which the product passport for mattresses becomes mandatory. What is known, however, is the process by which that date will come about. Article 18 of the ESPR describes how the Commission prioritises which product groups are first in line and how a work plan is drawn up for them. The Commission's current work plan for the period 2025-2030 names mattresses as a product group for which a delegated act is being prepared, with an expectation that that act could be published in the course of 2028. This is a planning date from a work plan, not a legally fixed obligation date — work plans shift, and the actual delegated act may contain its own transition period before the obligation takes effect. Until the act is in place, there is no passport requirement for mattresses under the ESPR. As soon as the Commission publishes the act, the date contained in it will be posted here.

What a manufacturer or importer can do with this

The sequence in which this is usually tackled does not start with the passport itself, but with the data that must go into it. Article 8 of the ESPR describes what kind of information a delegated act may prescribe in a product passport — think of material composition, origin, repair and recycling information. Much of that data already exists with the manufacturer or importer, it is just not always in one central location or in an interchangeable format. Mapping out which data already exists, where it comes from (own production, suppliers, import documentation) and who is responsible for it is something that can be done independently of the final date. The same applies to following the work plan: the delegated act for mattresses will be published on EUR-Lex and announced through the usual EU channels, and that is the moment when the concrete requirements, the implementation date and any transition period become known. Waiting to begin all preparations until that publication is an option; organising the data in advance is also an option, and narrows the gap to the eventual obligation.

Where this comes from: Article 18 and Article 4/8 of the ESPR

The power to make the product passport mandatory per product group lies with the Commission through delegated acts, as described in Article 4 of the ESPR (Regulation (EU) 2024/1781). Article 8 of that same regulation determines which elements such a delegated act must or can regulate, including the content of the passport. Article 18 describes the prioritisation mechanism and the work plan by which the Commission establishes for which product groups — including mattresses — such an act is to be prepared first, and according to which timeline. For mattresses, the act itself has not been published at this time; the regulation thus provides the framework and procedure, but no date yet.

Those who wish to follow this without repeatedly checking the EUR-Lex pages themselves would do best to organise their own product data now — materials, origin, suppliers — so that filling in a passport will later be a matter of transferring data rather than researching it anew. This page will be updated as soon as the delegated act for mattresses has been published, with the date then in force.

Where this is based on

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 (Regulation (EU) 2024/1781) is the framework regulation: it determines how the European Commission may address product groups, but does not itself impose any obligation on a mattress manufacturer or importer. That obligation only comes with a delegated act per product group, as described in what a delegated act is and why it determines what you must do. For mattresses, that act does not yet exist. Nevertheless, it is useful to know now what will be expected of a company later on, because preparation takes time.

Knowing whether your product falls under the regulation

Article 18 of the ESPR describes how the Commission prioritises product groups for a work plan. Mattresses are on the list to be addressed, but the precise scope — which mattresses, which variants, which exceptions — will only emerge from the delegated act itself. A company with 10 to 100 employees is well advised to already inventory which part of its assortment is likely to fall under the regulation, so that this inventory does not begin only once the text is published. The page on whether the digital product passport applies to your mattresses and the page on which products in the mattress industry fall under the ESPR provide an initial guide for that.

Getting data in order before the obligation takes effect

Article 8 of the ESPR describes what a delegated act can prescribe: from material composition to repair information to sustainability characteristics. For mattresses, the exact data set has not yet been established, but the direction is predictable on the basis of what already happens in comparable product groups. A company that now checks which data on filling, cover, base and origin are available — and which still need to be requested from suppliers — will save itself time pressure once the act is in place. More on the expected content can be found on the page on what data will be included in the product passport for mattresses.

Following when the delegated act is published

As long as the act is not published, there is no statutory deadline. The ESPR work plan 2025-2030 mentions a delegated act for mattresses as expected in 2028, but that is a plan, not a fixed moment. A company that depends on this obligation — for example because investment decisions are already being made on ERP systems or supplier data — is well advised to follow the publication of the EU work plan and the Official Journal, rather than build on an estimated date.

Where things go wrong in practice

A few situations come up repeatedly with companies preparing for an obligation that does not yet exist.

An incorrect date is used as a fixed reference point. There are already estimates circulating in the industry ("2027", "2030") that are cited here and there as certainty in quotes or internal plans, while the only fixed anchor point is the actual publication of the delegated act.

Suppliers are contacted too late. Material data on filling, foam, covers and base structures often come from multiple parties in the supply chain. Those who wait until the obligation officially takes effect will only then discover that some suppliers do not routinely maintain this data.

Box springs and composite products are not examined separately. A box spring consists of multiple components that may each be treated differently. Companies that only make this distinction once the regulation takes effect fall behind in understanding which component gets which passport — see whether a box spring receives one passport or multiple.

Toppers and covers are forgotten in planning. A mattress is often sold separately from the topper or cover, but it is not certain that these accessories fall outside the regulation. Companies that only include the core product in their preparation may miss part of their assortment — further explanation can be found on the page on whether a mattress topper or cover must also have its own product passport.

Hotel procurement and business customers are not informed. Hotel purchasers increasingly ask for product passports in advance, even though the obligation does not yet exist. A supplier who has no answer to this runs the risk of a difficult conversation while their own preparation is on schedule.

What you can record

An overview of your own assortment with, per product line, an assessment of whether it falls under the future regulation, based on the pages on scope.
A list of suppliers per material component (filling, cover, foam, base structure) with a note indicating which data are already being supplied and which are not yet.
An internal agreement on who within the company monitors the publication of the EU work plan and the Official Journal, so that a change is not noticed by chance.
A template for data collection per mattress type, so that the switch to a mandatory passport becomes a matter of completion rather than starting from scratch.
A brief internal note on the status of box springs, toppers and covers in your own assortment, with reference to the relevant knowledge bank pages for when the question comes from a customer or purchaser.
A communication line to business customers, such as hotel purchasing, about the expected schedule — without presenting a date as a commitment. For supplies to the hotel industry, there is additional guidance on the page on whether the product passport also applies to mattresses supplied to hotels.

As soon as the delegated act for mattresses is published, this page will be updated with the actual date and the associated obligations.

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, checked by a human on 2026-08-22. Is something wrong? Let us know — corrections are given priority.