What does a competent authority ask for during a mattress inspection?

What you concretely must do

What is expected of you

A supervisor who visits a mattress manufacturer or importer does not look at loose documents but at a coherent whole: can the company demonstrate that the product is what it claims to be, and is that demonstrable at the moment it is requested. Regulation (EU) 2019/1020 on market surveillance regulates what powers a supervisor has in this regard, and Article 27 of the ESPR (Regulation (EU) 2024/1781) describes what obligations rest on the manufacturer. For a company with 10 to 100 employees, this amounts to a few concrete expectations.

Able to provide technical documentation

The supervisor may request the technical documentation that forms the basis of the product passport: material composition, origin of raw materials, test results, declarations of conformity. This is not marketing text but underlying evidence. For a medium-sized company, this means that these documents must not lie separately with different suppliers or departments, but must be retrievable in one place — even if the person who did the purchasing no longer works there.

Demonstrating that the passport fits the product

Regulation 2019/1020 is based on traceability: a supervisor must be able to link a product to the correct documentation, and vice versa. For mattresses with a digital product passport, this means that the QR code or data carrier on the physical product must lead to the passport data that actually belongs to that batch or model. A mismatch — for example because a production change was not implemented in the passport — is precisely the kind of discrepancy that an inspection is aimed at.

Cooperating with the inspection within a reasonable timeframe

Article 27 of the ESPR places an obligation on the manufacturer to provide information and documentation on request. Regulation 2019/1020 adds that this must be done within a timeframe set by the supervisor. For a company with a limited overhead structure — no separate compliance department, often one or two people who handle quality and compliance alongside other duties — the practical question is: who is internally responsible once such a request arrives, and how quickly can that person produce the requested documents.

Being able to take corrective measures if something is not right

If a supervisor identifies a discrepancy, Regulation 2019/1020 expects the market participant to cooperate in remedying it — this may involve adjusting documentation, informing customers, or taking further measures. For a manufacturer or importer, this means that there must be an internal process to address such a notification, rather than having to improvise at the moment itself.

Where things go wrong in practice

The documentation exists, but no one knows where. At companies that grow through loose Excel files and email exchanges with suppliers, the underlying data for the passport often exists, but is not maintained centrally and up to date. During an inspection, it then takes days to put together something that should actually have been available within hours.

The passport and the physical inventory diverge. A production change — a different filling, a different supplier of ticking — is implemented in the factory but not in the passport that is already linked to the QR code. This occurs particularly with stock of mattresses that is already in place when the rules come into force: older batches may technically differ from what is now in the passport.

Returns receive no attention in the system. A mattress that comes back after trial sleep and re-enters the chain raises the question of whether the associated passport is still correct, or whether something has changed in the product's status. Anyone who does not have a fixed procedure for this, see what to do with mattresses that come back after trial sleep, runs the risk that a supervisor will find an inconsistency between physical product and digital data.

Shop staff cannot answer a follow-up question. A supervisor — or a customer — who inquires in the store about the origin of a product passport often finds staff who know that there is a QR code, but not what it contains or who is responsible for it. This can be prevented by preparing staff for this, see how you inform your shop staff about the digital product passport.

Unclear about who within the company is responsible. In smaller and medium-sized enterprises, there is often no separate legal or compliance function. If a request from a supervisor comes in at the sales department instead of to someone who knows the documentation, valuable time is lost finding the right person within the company.

What you can record

• An overview of which technical documentation belongs to which mattress model or which production line, with a fixed place where this is kept.
• An internal designation of who is responsible for answering a request from a supervisor, including a replacement in case of absence.
• A procedure for updating the product passport as soon as something in the product changes — material, supplier, composition — so that passport and physical product do not diverge.
• A fixed procedure for returns after trial sleeping, so that it is clear whether and how the product passport is checked or adjusted in this process.
• Instructions for store staff about what they can and cannot say if a customer or inspector asks about the product passport.
• A log of previous requests or inspections, with what was asked and what was provided — that helps with the next inspection.

Anyone who still needs to determine whether and how all of this applies to their own assortment usually starts with the question does the digital product passport apply to my mattresses, and can proceed from there through the steps described in how do I approach the digital product passport for mattresses step by step.