do I need special software to create a digital product passport
No, no special software required by regulation
The ESPR does not prescribe a particular software package, system or brand. What the regulation does establish are requirements for the outcome: the digital product passport must contain data that is accessible in a specified manner via a data carrier, it must comply with certain technical and organisational requirements, and it must be consultable by those entitled to do so. How a manufacturer or importer arranges this technically — with a self-developed system, a module in the ERP package, or a service from an external party — is not laid down in law. There is therefore no mandatory "product passport software" that appears on a list somewhere and must be purchased. What there must be is a functioning whole that meets the requirements of the regulation, and that is a different question from which software is used for it.
For mattresses this applies, for the administration behind it not automatically
This freedom of means applies to the digital product passport for mattresses as the ESPR will require it: the data carrier, the storage and the disclosure of the passport data. It does not apply to everything else a manufacturer or importer already uses or must use in terms of software. An accounting system, an inventory management package or a CE marking file fall outside this regulation and have their own rules. Nor does it apply to the question of whether a particular system is "good enough" — that is not assessed on the basis of the brand or supplier of the software, but on whether the outcome meets the requirements of the regulation. A spreadsheet that happens to meet all requirements is in theory just as valid as an expensive specialist solution; conversely, an expensive system does not automatically comply simply because it is expensive.
No fixed date yet, but already fixed requirements for the design
When the digital product passport becomes mandatory for mattresses is not yet fixed; that will follow from a delegated act that still needs to be published for this product category. Until that time, there is no obligation to already operate a product passport. What is already fixed, however, are the general technical requirements in the ESPR that a digital product passport will have to meet, regardless of which software it is built with. These requirements concern, amongst other things, interoperability, the use of open standards and the manner in which data must be made accessible. Those who are already choosing or developing software can therefore take these requirements as a starting point, even though the mandatory entry date for mattresses themselves is not yet known.
Where to begin when choosing a system
The practical sequence does not begin with software, but with the data: first it must be clarified which product information will eventually go into the passport, before looking at how that information is technically stored and disclosed. After that comes the question of how each mattress receives a unique identification code , because that code is the link between the physical product and the digital data about it. Next, it is a choice whether that process is set up internally or outsourced to a party that handles storage and disclosure — that is precisely where a platform such as this one fits in, by compiling the passport from the supplied data and providing the hosting and the QR data carrier. For companies that already work with an ERP or inventory system, it is subsequently relevant whether and how that system can be linked to the product passport, so that data does not have to be entered twice. Those who prefer to see the bigger picture first before making a system choice can also start with the question of how the European product passport register relates to their own passport, because that register is a mandatory component alongside whichever software is chosen.
This follows from articles 9, 10 and 11 of the ESPR
The basis is established in Article 9 of the ESPR (Regulation (EU) 2024/1781), which introduces the digital product passport as an instrument. Article 10 of the ESPR elaborates on the substantive requirements that a passport must meet, without prescribing a specific technology or supplier. Article 11 of the ESPR specifically addresses the technical design and operation of the digital product passport, and states requirements such as interoperability and the use of open standards — requirements that apply to the result, not to the tool used to achieve that result. Together, these three articles demonstrate that the regulation is designed functionally: it governs what a passport must be capable of and how it must be accessible, and leaves the choice of software to those who compile the passport.
Anyone who wishes to prepare now can best start by organizing their own product data and establishing an identification system per mattress, so that a solid foundation is in place once the delegated act for mattresses is published — the choice for a specific software system can follow thereafter, based on the technical requirements that will then apply.
Where this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 11 (technical design and operation of the digital product passport)
- Regulation (EU) 2024/1781 (ESPR), Article 10 (requirements for the digital product passport)
- Regulation (EU) 2024/1781 (ESPR), Article 9 (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 passport that is readable via open standards
Article 10 of the ESPR (Regulation (EU) 2024/1781) requires that the digital product passport operates on the basis of open, interoperable standards. This means that data must not be locked in a closed, proprietary file format that can only be opened with one specific program. For a mattress manufacturer with 10 to 100 employees, this above all means that the choice of a system or platform must be tested against this requirement: can the data be extracted, and can it be read by other parties without them having exactly the same software as you?
Accessibility via a data carrier, not via an app
Article 11 governs how the passport works technically: via a data carrier (in practice often a QR code) that points to the data. The consumer, competent authority or trading partner must be able to access that data without requiring a separate application provided by you. In practice, this means that an ordinary smartphone with a camera and a browser must be sufficient. Anyone considering having a custom app built to display the passport does so as an additional service — not because the regulation requires an app. How that data carrier ends up on the product is described on the page about how the QR code for the product passport gets onto your mattresses.
Linking to a unique identification number
Article 9 links the passport to a unique product or model identification. This requires a way to link each passport to the correct physical product. For companies that already work with batch numbers, EAN codes or internal article codes, this is usually a matter of consistently using this existing numbering in the passport system. How this link is set up in practice is explained on the page about how to give each product a unique identification code.
Data that remain current and traceable
Articles 9 and 10 together imply that the passport is not a snapshot that can be forgotten after publication, but a collection of data that remains linked to a specific product for as long as the passport must be available. This requires a company to have a way of knowing which information belongs to which product, even if questions arise later about a mattress that was sold a few years ago.
Where things go wrong in practice
A manufacturer has a passport created in a program that works well, but whose supplier only provides the data as a PDF or as a screenshot. This is readable for a human, but not machine-readable as Article 10 intends — the underlying data must be structurally retrievable, not merely displayed visually.
A company builds its own app to display the passport, assuming this is mandatory. This costs time and money in development, while article 11 actually calls for accessibility without special software — a simple web page that opens via the QR code meets that purpose.
An importer uses a new, ad-hoc Excel file for each delivery that is manually converted into a passport. Once volume increases, errors emerge in the link between product and passport, and it becomes unclear which passport belongs to which batch.
A manufacturer chooses a system without checking whether data can ever be exported from it. When later switching to another platform, or when the hosting party stops operating, the data turns out to be locked in with a single supplier. What this entails is described on the page about what happens to your product passports if the hosting party stops.
A company thinks the passport system must be separate from its own business operations, and enters all product data twice: once in the ERP system, once in the passport system. This doubles the work and increases the risk of discrepancies between both sources.
What you can record
- An overview of the file formats used by the chosen systemand whether these are open and exportable — this can be checked against the interoperability requirement from article 10.
- A description of how the data carrier (QR code) provides access to the passportwithout requiring a separate app, as intended in article 11.
- A linking table between internal product codes and passport identification numbersso that at any time it can be traced which passport belongs to which physical product. Companies wishing to combine systems for this can look into the possibilities described on the page about linking the product passport to an ERP or inventory system.
- Agreements with the software supplier or platform on data export, long-term availability, and what happens when the service ends.
- An internal process for maintaining product dataso that changes in material composition or other characteristics consistently flow through into the passport, rather than being maintained separately and in duplicate.
For companies that make customised mattresses, it is also good to define how individual variants are processed in the passport system — that process often differs from standard production and is explained on the page about how the product passport works for made-to-measure mattresses.
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, reviewed by a human on 2026-09-05. Is something not correct? Let us know — corrections are given priority.