What can I do now while the rules are not yet final?

Start collecting data and mapping the supply chain now

What a mattress manufacturer, importer or specialist retailer can do right now is to get the basics in order: collect material data, map out suppliers and record what is already known about the composition, origin and processing of a mattress. This work will be needed as soon as the delegated act for mattresses is published, and it is already useful now — for your own quality assurance, for conversations with buyers who ask about sustainability, and to avoid time pressure later if the obligation does get a fixed date. The ESPR itself (Regulation (EU) 2024/1781) is already in force; it is the product-specific implementation for mattresses that is still to come. That sequence — framework regulation first, product rules later via a separate decision — is precisely why "not yet mandatory" is not the same as "nothing to do yet".

For whom this is relevant, and for what it is not

This is relevant for parties that place mattresses on the EU market or procure them: manufacturers, importers, wholesalers, specialist bed retailers and hotel purchasing departments. It concerns preparation for an obligation that is still to be established, not an obligation that already applies today. There is therefore no legal obligation to maintain a digital product passport for mattresses yet, and no one can say with certainty right now which data will be mandatory or from which point in time. Nor does this concern other product groups — the ESPR works with a prioritisation process per product category, and mattresses are going through that process at their own pace, independently of, for example, textiles or electronics. And it is not about mattresses that have already been sold: preparation is aimed at what comes to market after the rules take effect, not at documenting existing stock with retroactive effect.

The date is not yet fixed

There is no fixed date on which the digital product passport for mattresses becomes mandatory. What is certain is the framework around it: the ESPR describes in Article 18 how the European Commission is working on a prioritisation and scheduling of product categories for which product-specific requirements are to be established. Mattresses are part of that process, but the product-specific delegated act — the decision that really determines what must be in the passport and from when — has not yet been published. Until that publication there is no concrete obligation for mattresses, and any date circulating here and there is an expectation, not an established fact. Once the delegated act is published, the date is fixed and this page will be updated.

What this concretely means, in the order to address it

The first step is internal: create an overview of the materials and components in a mattress, including origin and suppliers. This overview often already exists in part in purchasing administration or quality files, but rarely in a way that is ready for a passport — it is worthwhile to consolidate it now. The second step is to organize the supplier chain: determine which supplier can provide which information, and where data is currently missing or scattered. Article 38 of the ESPR describes that actors in the supply chain can be required to provide information necessary for compliance with product-specific requirements; it is therefore wise to know now who in the chain has which data, rather than discovering that only when a deadline is already running. The third step is to assign internally who will be responsible for compiling and keeping passport data up to date — at a manufacturer usually quality or compliance, at an importer often purchasing. The fourth step is to monitor the progress of the ESPR work plan, so that it is known when mattresses as a product category come up specifically. The fifth step, finally, is to check early on how data will need to be made available digitally — via a data carrier such as a QR code — so that this does not come as a separate action afterwards, but aligns with the product data already built up.

The legal basis: Article 18 and Article 38 of the ESPR

The fact that there is no fixed obligation yet follows from Article 18 of Regulation (EU) 2024/1781: this article regulates the process of prioritization and planning by which the Commission determines for which product groups, in which order, product-specific requirements are developed through delegated acts. That it makes sense for mattresses to prepare for this, even without a fixed date, follows from Article 38: this article establishes that actors in the supply chain can be required to provide information necessary to comply with the requirements, which means that the data flow through the chain will in any case become part of how the passport will be filled in.

Anyone who wants to start now begins by collecting material and supplier data internally and mapping their own chain — that work is never wasted, regardless of when the delegated act for mattresses is published.