What is a digital product passport for mattresses?

What you concretely must do

A digital product passport is, in essence, a digital file attached to a product: data on materials, origin, repair and end-of-life processing, made accessible via a data carrier on or with the product. For mattresses, this means a QR code on the label, which refers to an online page with data for that specific mattress or product group. Article 9 of the ESPR (Regulation (EU) 2024/1781) stipulates that products falling under the regulation must be provided with such a passport. Article 10 of the ESPR sets out the technical and content requirements to which that passport must comply.

The passport is not a replacement for existing mandatory labelling or certificates, but a layer above it: a central, digitally accessible source in which data that would otherwise be scattered across invoices, technical datasheets and packaging information comes together in one place. For the mattress industry, this is a change compared to current practice, in which a customer or buyer often has to ask for composition, warranty conditions or maintenance instructions themselves.

What is expected of you

A data carrier on or with the product

The product receives a physical or digital reference — usually a QR code — that leads to the passport. For a mattress manufacturer, this means that the label or packaging is adapted, and a technical choice is made about where and how that code is placed: on the mattress label itself, on the packaging, or on both. For a company with 10 to 100 employees, this is primarily a production and procurement technical adaptation: labels and packaging must be reviewed, and a supplier or service must be chosen that generates the QR codes and links them to the correct data.

Correct and up-to-date data behind the data carrier

Article 10 of the ESPR sets requirements for the content and accessibility of the passport. This means that the data behind the QR code must be correct and must be kept up to date. For a manufacturer with an assortment of dozens of mattress models, this is a matter of internal discipline: who updates the data when a supplier of filling material changes, and who checks that the passport still matches the product actually being sold? This is a recurring task, not a one-time action at launch.

Accessibility throughout the product's lifetime

The passport must remain accessible, even after the mattress has been sold and is in use for years. For a manufacturer or importer, this means there must be a party that guarantees the hosting and availability of that data, even if the company itself switches software suppliers, undergoes a takeover, or discontinues a product line. This is precisely the part for which matrapas.eu was set up: the data is compiled from the input of the manufacturer or importer, and hosted for ten years, so that availability does not depend on the internal IT of a single company.

Knowing which products are involved

Not every mattress a manufacturer makes automatically falls under these rules in the same way, and the regulation itself mainly sets out the framework — the specific product groups and requirements come via delegated acts. A company that wants to know whether a specific assortment falls under the obligation should review this per product line. See about this which products in the mattress industry fall under the ESPR and, more specifically for your own situation, whether the product passport applies to your own mattresses.

Where things go wrong in practice

One situation is that a manufacturer does place a QR code, but does not keep the underlying page up to date when a material changes — the code then refers to data that no longer matches the delivered product.

A second is that responsibility remains unclear between manufacturer and importer when a mattress is produced outside the EU: who compiles the data, and who is the contact point if the data carrier does not work or the page is offline?

A third situation arises with composite products. A box spring consists of a mattress, a base and sometimes a separate headboard, and the question of whether that receives one product passport or multiple is often raised too late in practice, meaning labels and documentation have to be adjusted afterwards. See whether a box spring receives one passport or multiple.

A fourth situation is that companies underestimate the hosting obligation: the product passport must not only exist at launch, but must remain accessible for years, even if the company itself switches software systems or if a product line is phased out.

A fifth, common situation is that smaller producers assume that the obligation only applies to large manufacturers, while the regulations make no general exception for this. See whether the product passport also applies to small companies.

What you can record

• An overview per product line of which mattresses, toppers and box spring components may fall under the obligation, including the question of whether a mattress topper or cover requires its own product passport.
• A list of the data maintained per mattress model: materials, origin, maintenance instructions and end-of-life treatment. See also which data are concretely expected in the product passport of mattresses are expected.
• An internal agreement on who is responsible for keeping the product passport data current in case of changes in composition or supplier.
• A file with the justification for why a particular product is or is not considered to fall under the obligation, including the assessment against the applicable delegated act — see what a delegated act is and why it is decisive.
• Agreements with suppliers and importers on who supplies which part of the product passport data, especially relevant when supplying to business customers such as the hotel industry.
• A documented procedure for hosting and availability of the product passport page, also following any change of software supplier.