Which data must I request from my mattress supplier?
Material origin, composition and documentation form the core
The data requested from a mattress supplier concern four main things: the composition of the materials used, the origin of raw materials, the presence of substances that fall under the attention of legislation, and documentation on sustainability, repair and end of life. This follows from the structure of the digital product passport as laid down in the ESPR: a passport brings together product information on sustainability, repairability, recyclability and the environmental impact of a product, and that information must come from somewhere. For a mattress manufacturer or importer, this means that a foam supplier, textile supplier or spring core producer is asked about precisely those categories: which materials have been processed, in what proportion, where they come from, and whether there are certificates or test reports that support this. The exact, mattress-specific list of mandatory data fields is not yet fixed — that follows from a delegated act that still needs to be published — but the direction of what will be asked is already fairly clear via Article 10 of the ESPR.
Who this applies to, and what does not yet apply
This question applies to everyone in the supply chain of a mattress: raw material suppliers, component manufacturers (foam, springs, textiles, adhesives), and the party that brings the end product to market. Article 38 of the ESPR stipulates that actors in the supply chain can be required to provide the information necessary to comply with the requirements of the regulation — this therefore affects not only the manufacturer that has the passport compiled, but also every link before it. What does not yet apply here is a concrete, enforceable obligation specifically for mattresses: the product group mattresses must first be included in a delegated act before the precise data fields and thresholds are fixed. Until that time, there is therefore no legal obligation to provide this data in passport form, although it may be prudent for your own business operations to start inventorying what is available.
No fixed date yet, but a work plan
There is no fixed date yet when this data must be mandatorily requested and processed. The ESPR work plan for the period 2025-2030 mentions a delegated act expected to be published in 2028, but this is an expectation from a work plan and not a fixed date. Once the delegated act for mattresses has been published, the actual entry date will be shown here. Until then, the general framework regulation of the ESPR already applies, but without a concrete obligation for mattresses to have a passport or to request data from suppliers. This does not mean there is nothing to do: practice shows that collecting this data takes time, especially when a supplier must also inquire with his own suppliers.
How this is approached in practice
The sequence most companies follow starts with an inventory of what is already available: safety data sheets, certificates (for example for foam or textiles), and any test reports already requested during procurement. This is followed by a conversation with each supplier about the four main categories: material composition (what percentage foam, latex, textiles, metals), origin (country of production, possibly of raw materials), substances of concern (whether and which substances have been used that fall under chemicals legislation), and documentation on durability (warranty periods, repair options, end-of-life instructions). A third step is to establish a contact point at each supplier for future updates, because data retrieved now will likely need to be kept current after publication of the mattress-specific rules throughout the entire product lifespan. Finally, it is practical to store this data in a structured manner — in a spreadsheet or digital file per product line — so that when the obligation takes effect, the data does not need to be collected from scratch again.
The legal basis: Article 10 and Article 38 of the ESPR
The content of the digital product passport is regulated in Article 10 of Regulation (EU) 2024/1781 (ESPR), which sets out which categories of information a passport should in principle contain. The obligation to actually provide that information within the supply chain is laid down in Article 38 of the same regulation, which sets requirements for actors in the supply chain. Together, these two articles form the framework within which, after publication of the product-specific delegated act for mattresses, it will be determined exactly which data are mandatory and from whom they must come.
What to do now
Those wishing to prepare now can best start by requesting the four main categories — material composition, origin, substances of concern and durability documentation — from the most important suppliers, and store that data in a structured manner. Matrapas.eu monitors publication of the delegated act for mattresses and will update this page as soon as the exact data fields and effective date are known.
Where this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 38 (requirements for actors in the supply chain)
- Regulation (EU) 2024/1781 (ESPR), Article 10 (requirements for the digital product passport)
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
A mattress manufacturer assembling the digital product passport depends on data supplied by suppliers of foam, springs, textiles and other components. Article 38 of the ESPR (Regulation (EU) 2024/1781) describes how actors in the supply chain provide the information needed to meet the obligations under the regulation. What this means in practice breaks down into a few recognisable points.
Determining which data your supplier must provide
Article 10 of the ESPR describes what information a digital product passport must contain: data on materials, origin, composition and other product properties relevant to the passport. For a company with 10 to 100 employees, this means that for each component — foam, springs, ticking, adhesive — a list is needed of exactly what the supplier provides. At a mattress manufacturer with multiple foam and spring suppliers, this quickly becomes varied, because not every supplier records the same data in the same way. More on that situation is in how do I combine data from different foam and spring suppliers in one passport.
Requesting data that is accurate and complete
It is not enough for a supplier to provide something — the data must also match what is actually in the component. For a company without its own laboratory, this often means relying on the supplier's own statement, possibly supplemented with certificates or test reports that the supplier already has. How that check can be implemented in practice is described on how do I check whether my supplier's data are correct.
Making agreements on the timing of delivery
Data that arrives too late delays the assembly of the passport. For a company that produces mattresses in series, it is practically relevant to agree in advance when a supplier will provide which data — at the first delivery of a new type of foam, with each batch, or annually if specifications are unchanged. This is typically something that is included in the purchase contract, as described in how do I record the delivery of product passport data in my purchase contract.
Requesting data appropriate to imports from outside the EU
For mattresses or components imported from outside the European Union, there is an additional layer: the importer often has less direct insight into production conditions than a manufacturer that produces itself. Which data is relevant in that context is explained on what does the product passport mean if I import mattresses from outside the European Union.
Where things go wrong in practice
A few situations come up repeatedly with companies requesting data from their suppliers for the first time.
A supplier provides data, but not in a form that can be used for the passport — for example a technical datasheet drawn up for a completely different purpose, without the specific material data that the passport requires.
A manufacturer requests data from the supplier's purchasing department, while knowledge of material composition is in the technical department. The answer therefore comes late, incomplete, or via an intermediary who cannot pass the question on properly.
With mattresses made from components from multiple suppliers — foam from one party, springs from another — it later turns out that no one has recorded who is providing which part of the data, creating gaps in the passport.
A supplier changes, for example from foam producer, without consideration of the consequences for a passport that has already been assembled based on data from the previous supplier. This touches on the question addressed on does the product passport remain accurate if I switch to a different mattress material supplier.
A supplier refuses to provide data because he fears that competitors will gain insight into his recipe or composition. This is particularly an issue with foam suppliers with their own formulation, and raises both the question of what to do if a supplier refuses — see my supplier is not providing the data — what can I do — and the possibility of arranging confidentiality contractually.
What you can record
- An overview per component (foam, springs, ticking, glue, other materials) of which data the supplier provides and in what form.
- An agreement on the timing of delivery: with the first order of a new material, with each batch, or periodically.
- A contact person at the supplier who is substantively responsible for the material data, not just a procurement contact.
- A provision in the purchase contract regarding the delivery of passport data, as explained on how do I record the delivery of product passport data in my purchase contract.
- A confidentiality agreement, when a supplier shares sensitive composition data that must not be distributed more broadly — see can I arrange an NDA with my supplier regarding the data for the passport.
- A fixed procedure for checking supplied data before it is included in the passport.
- A file per supplier with the data, certificates and test reports received, so that these can be found again in case of a change of supplier or in a subsequent inspection.
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.