do I need to update the product passport if I change the foam or filling
A modified composition belongs in an accurate product passport
When the foam or filling of a mattress changes, the digital product passport in principle concerns a different product than the passport drawn up for the original composition. The passport is linked to a specific product with specific properties — material composition, origin of raw materials, possibly also flame retardants or other substances relevant to Annex requirements. If that composition changes, the information in the existing passport no longer matches the product that is actually being sold. This is not a matter of "updating the passport a little", but of ensuring that the data attached to a mattress actually concerns that mattress.
Who this applies to, and what a minor adjustment is not
This particularly affects mattress manufacturers and parties classified as manufacturers, such as a retailer who has mattresses produced under its own brand — see I sell mattresses under my own brand — what obligations do I have?. Not every adjustment to a mattress is immediately relevant to the passport. A change in the cover, the stitching, or a colour variant with no impact on material composition generally does not affect the core data on which the passport is based. It concerns modifications that make the information in the passport factually incorrect: a different type of foam, a different filling, a different origin of raw materials, or a different ratio of materials. In case of doubt as to whether a specific adjustment falls within or outside that boundary, this is a question to be assessed on a case-by-case basis in light of what the passport states precisely for that product.
Important is also the distinction between an adjustment to an existing model and a new model. A mattress with different foam is in practice often a different article with its own passport, not an update of the old one. This aligns with how responsibility for the passport is already distributed: the party that assembles the product and places it on the market also determines the data that goes into it — see Who is responsible for the product passport for mattresses?.
No fixed date yet, but a fixed line in the Regulation
When this obligation will apply in practice to mattresses is not yet fixed. The ESPR (Regulation (EU) 2024/1781) is the framework regulation; the specific requirements for mattresses will come in a delegated act which, according to the European Commission's work plan for the period 2025-2030, is expected to be adopted. Once that act is published, the date will be stated here. Until then, it is already fixed what the Regulation requires in general terms of a digital product passport: it must represent the product information correctly and up to date, as follows from Article 9 and Article 10 of the ESPR. This basic rule does not change when the precise entry into force date for mattresses becomes known — that date determines from when the obligation applies, not what the obligation entails.
How this is handled in practice
Those who modify the composition of a mattress are well advised to first establish whether it is a modification of an existing model or a new article — this determines whether a new passport is needed or an updated version of the existing one. Next, it is important to ascertain which party supplies the data on the new composition: with an own production line, that is the manufacturer itself; with procurement from a third party, that is often with that supplier — this aligns with the question who is responsible for the passport if I have mattresses made under my own brand. Then it is a matter of determining from which moment the modified mattress is actually being sold, because from that moment on the information attached to that mattress must match what is actually in it. Finally, it is advisable to check whether earlier stock with the old composition continues to be sold alongside the new version — in that case there are in fact two products side by side, each with its own, accurate data. Incorrect data in a passport does not only affect the manufacturer: downstream parties who rely on that data can also be affected, as described at who is liable if there is incorrect information in the product passport of a mattress.
The basis: Articles 9 and 10 of the ESPR
That a product passport must contain current and accurate product information follows from Article 9 of the ESPR (Regulation (EU) 2024/1781), which describes the digital product passport as an instrument, and from Article 10, which establishes the requirements for the content and functioning of that passport. For the manner in which product properties are determined — relevant when a new composition must be tested or calculated again — the Regulation refers to Article 39, concerning test, measurement and calculation methods. The concrete product group requirements for mattresses, including what exactly counts as a modification that affects the passport, follow from the delegated act that still needs to be published.
Anyone currently developing a mattress with a new foam or filling composition would do well to properly document the data on that new composition now — material origin, composition, any substances relevant to future requirements — so that this information is ready at the moment the obligation for mattresses takes effect.
Where this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 10 (requirements for the digital product passport)
- Regulation (EU) 2024/1781 (ESPR), Article 9 (digital product passport)
- Regulation (EU) 2024/1781 (ESPR), Article 39 (test, measurement and calculation methods)
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 is not a fixed entity. Manufacturers change foam types, switch fillings, adapt the cover layer or change a supplier of a raw material. The question that arises: must the product passport change accordingly, or does the existing passport remain valid? The answer is linked to what a product passport is according to the ESPR: a supporting layer of information that belongs to a specific product or product model, not a separate document that happens to be attached somewhere.
The passport must correspond with the product on the market
Article 9 of the ESPR (Regulation (EU) 2024/1781) describes the digital product passport as a collection of data that is specific to a product, product model or batch. This means that the data in the passport should match what is actually in the mattress. If the composition changes — a different type of foam, a different filling, a different percentage of recycled material — then the old information no longer matches the new product. For a company with 10 to 100 employees, this means that a change in production is not only a matter for R&D or purchasing, but must also be a signal to whoever manages or arranges the passport.
The content of the passport follows from Article 10 and the product-specific requirements
Article 10 of the ESPR (Regulation (EU) 2024/1781) describes what kind of information a product passport must be able to contain: data on materials, composition, origin, repair and recycling options and the like, insofar as these have been made relevant for the product category via a delegated act. For mattresses, the precise list of mandatory fields will be established in such a product-specific act. In practice, this means for a manufacturer that when the material composition changes, it affects exactly the fields that form the core of the passport — not an incidental detail. A change in filling or foam is therefore typically something that goes directly into the core fields of the passport.
Data must be traceable to a method
Article 39 of the ESPR (Regulation (EU) 2024/1781) concerns the test, measurement and calculation methods used to determine product information. This is relevant as soon as a foam or filling changes: the properties that were previously measured or calculated for the old material do not automatically apply to the new one. For a company, this means that a material change in practice often requires new measurements, new calculations, or at least a new substantiation — not just new text in the passport.
Who must make the change depends on the role in the chain
Who is responsible for maintaining the passport is not the same for every company. This is detailed on the page about who is responsible for the product passport of mattresses. A manufacturer who changes the composition itself will generally have to have that carried out itself. A company that has mattresses made under its own brand is in a different position: the question of who actually supplies the change and who ensures that the passport is correct again is then a matter between the own brand and the manufacturer who actually produces the mattress. That relationship is described on the page about the relationship between private label and manufacturer.
Where things go wrong in practice
A few situations come up repeatedly in practice.
A manufacturer switches foam suppliers because the original supplier no longer supplies, and assumes that the properties are "similar enough" to leave the passport unchanged. The composition in the passport then no longer matches the actual product.
An assortment is "made more sustainable": part of the synthetic filling is replaced by recycled material, as a marketing claim on the packaging. The passport is not adapted because the change is seen as an improvement, not as something that "must be reported" — while it is a factual change in composition.
A private label brand receives a seasonal update of the mattress model from the manufacturer, without explicitly communicating that the filling has been adjusted. The brand that sells it does not know that the underlying passport is no longer up to date. What a private label brand should do in that regard is described on the page selling under your own brand.
A manufacturer tests a new foam type in a limited batch, as a trial, and uses the passport of the standard model because there is "still no definitive decision" on the switch. The batch that is sold then deviates from what the passport describes.
A distributor notices that a delivered batch differs from previous batches — different smell, different weight — but has no way to check whether that corresponds with an adjustment in the passport, because there is no agreement on how changes are communicated. What is expected of a distributor in this regard is on the page about obligations of a distributor or trader.
What you can record
- An internal process in which every change in material composition — foam, filling, cover, coating — automatically forms a control point for the associated product passport, before the modified product is sold.
- An overview of which product models are linked to which passport, so that a change in one model does not accidentally affect the passport of another model.
- Agreements with suppliers of foam and filling material about reporting changes in their own raw material, even if that change seems small from their side.
- A documented procedure with the party that actually compiles or hosts the passport, about the timeframe within which a material change is communicated and processed.
- For private label constructions: a contractual agreement about who informs the manufacturer of a change, and who is responsible for having the passport updated — a subject that relates to the question of who is liable for incorrect data in the product passport.
- Underlying test reports or calculations that support the new material composition, so that the data in the passport remain traceable to a method as intended in Article 39 of the ESPR.
- A dating system that makes clear from which point a modified passport applies to which batch or production date, so that older and newer mattresses are not confused with each other.
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.