What does the ESPR change for the mattress industry?

What you concretely must do

The ESPR — Regulation (EU) 2024/1781 — is the framework regulation by which the EU establishes a system for ecodesign of products. For mattresses, this concretely means that requirements will apply to how a mattress is made, what it contains, how long it lasts and what information must be available about it. Article 1 of the regulation describes that the scope covers virtually all physical products, with a system of delegated acts per product group. Mattresses are not mentioned by name in the regulation itself; whether and how the requirements apply in detail depends on such a product-specific act. What that entails and why it is decisive is described on the page about what a delegated act is and why it determines what you must do.

For a manufacturer, importer or specialist retailer, the key change is therefore not one new rule, but a new way of working: information about the product must be structured, digital and accessible for the long term.

What is expected of you

Structuring product information and making it digitally accessible

The ESPR works with the digital product passport as a tool to disclose information about a product: materials, origin, repair and recycling options, and more. For a company with 10 to 100 employees, this means that data that may now be scattered across purchasing files, technical sheets and emails with suppliers must be brought together in a fixed structure. Which data specifically applies to mattresses is described on the page about which data goes into the passport of mattresses.

Determining whether your own product falls under the regulation

Not every mattress product is automatically the same case. A basic mattress, a boxspring, a topper and a mattress cover are different products with potentially different positions in the system. For companies that carry assortments with variants and accessories, this is a real investigative task. A boxspring, for example, consists of multiple components, and the question of whether this will later result in one passport or multiple passports is addressed on the page about boxsprings and composite beds. For toppers and covers separately, a similar question applies, which is covered on the page about mattress covers and toppers separately.

Making distinctions between target groups and sales channels

Part of the mattress industry does not only supply consumers via retail, but also supplies the hotel sector, or occasionally sells a mattress directly between private individuals, or trades second-hand mattresses. Each of these situations raises its own question about whether and how the passport applies. For supply to the hotel industry, this is worked out on the page about mattresses for the hotel industry, for sales between private individuals on the page about private sales between consumers, and for the second-hand market on the page about selling second-hand mattresses.

Anticipating without waiting for the definitive date

Because the delegated act for mattresses has not yet been published, there is no hard obligation and no fixed date yet. This does not mean there is nothing to do: companies that now bring their material data, supplier information and product composition into order are better prepared once the requirements become concrete. When that obligation is expected and what is known about it is described on the page about when the product passport becomes mandatory for mattresses.

Where things go wrong in practice

A few situations keep coming up with companies preparing for this:

• The assumption that small companies will be exempt. The regulation does not make a general exception for company size in its framework provisions; whether and how smaller companies are treated differently is something that must emerge per product group in the delegated act. Anyone who assumes without verification that it "does not apply to us because we are small" risks that assumption later proving incorrect.

• Material data that are not available at product level. Many mattress manufacturers work with varying foam, spring and covering suppliers per season or per batch. If that data is not consistently recorded per product variant, it creates a reconstruction task afterwards that takes a lot of time.

• Confusion between the base product and accessories. A topper or cover is now often considered an ancillary product, whereas the question of whether such an accessory requires its own passport must be assessed separately.

• Lack of clarity with composite products. With box springs consisting of mattress, base frame and headboard, companies face the question of whether this is one article with one passport, or multiple components that each must be assessed separately.

• No distinction between sales channels. A specialist retailer that supplies both consumers and hotel chains sometimes treats this as one and the same sale, whereas the applicability of rules can differ per distribution channel.

What you can record

Even without a definitive date, it is practical to bring structure now. Consider:

• An overview per product line of materials, components and suppliers, traceable down to the level of a specific mattress variant.
• A list of all product types the company carries (mattresses, toppers, covers, box springs) with a note on which question still remains open — for example via the classification used on the page on which products in the mattress industry fall under the ESPR.
• Agreements with suppliers on the timely and structured provision of material and composition data, so that this does not have to be reconstructed afterwards.
• A file per product group with the status of the assessment: does it fall under the passport, and on what basis has that been determined — an initial orientation on this is provided by the page on or whether the product passport applies to your own mattresses.
• A fixed point of contact within the company that monitors the progress of the delegated act, so that changes are not noticed only at the moment they already apply.

These documents together do not constitute a legal obligation at this time, but they do provide a basis that considerably simplifies the process once the regulation for mattresses becomes concrete.