The mistake: everyone thinks someone else is handling it
When mattresses are made, purchased and sold by multiple parties, there is often a gap between what the regulation requires and what happens in practice. The manufacturer assumes the importer will submit the data. The importer thinks the software supplier will automatically compile the passport. And the shop or hotel buyer assumes the product is already complete when it arrives. The result: nobody has really taken on the task, and you usually only find out when a supervisor or business customer asks for the passport.
This mistake does not stem from unwillingness. The regulation works with roles such as manufacturer, importer and distributor, and these roles determine who bears which obligation. But a role in the legal text is different from a task on the work floor. Who within your company presses the button to submit, check or update data is not automatically determined anywhere. You have to assign this yourself.
Why this goes wrong more often than you would think
It happens most often at companies that work with multiple links in the chain: a manufacturer in another EU country, an importer who represents the brand, and a shop that sells under its own name. Each link sees part of the process, but nobody has an overview of the whole. It also happens at smaller companies: a director handles the first registration, but if the model changes or a supplier switches, there is nobody left to pay attention to that.
A second reason is that people read the regulation as a one-time action. They think: the passport is there, so it is sorted. But a passport that is not kept up to date is not the same as a passport that is correct. Who feels responsible for that update is precisely the question that often nobody answers before it is needed.
What goes wrong when nobody takes it on
If responsibility is not assigned, two types of problems usually arise. The first is that data is missing at the moment it is needed, for example during an inspection or during a large purchase order from a hotel chain. The second is that data does exist, but no longer correct because a material or supplier has changed without anyone updating the passport accordingly. Both situations can be prevented by determining in advance who does which step, rather than discovering it afterwards.
How you prevent it: put it in writing, not as an assumption but as an agreement
The solution does not lie in legal precision, but in a simple internal agreement: who supplies the source data, who checks whether it is complete, and who reports a change in the product. This can be one person at a small company, or a fixed division of tasks between procurement, quality and an external party at a larger company. What is important is that it is documented somewhere, and not just in someone's head.
The same applies to contact with your software supplier or the platform that hosts the passport. Explicitly agree on who does the submission and who triggers the update if something changes in the model. A supplier can technically prepare and host the passport, but the factual accuracy of the data remains the responsibility of the party that submitted it. sorted out per situation which role has which task provides an overview of how that division works in practice for manufacturers, importers and sellers.
If you are not sure which role your company exactly fulfills in the chain, that is a good starting point before you document anything. get a first indication in a few questions shows approximately where your company stands, without you having to go through the entire regulation first.
What you can and cannot agree with a software supplier
A software provider or hosting party can handle the technical part: generating the QR code, storing the data for ten years, and keeping the product passport accessible. What a provider cannot determine for you is who within your organization is responsible for the accuracy of the data at any given time. This distinction is important to clarify, especially because supervisory authorities in different EU countries may take different views on it. For questions about how data is collected and stored, you can also check how data is stored and secured before you transfer a task to an external party.
This division of tasks is not a matter of bringing in a lawyer for every detail, but rather something you can discuss with an advisor or the competent supervisory authority if it concerns your specific situation. The regulation itself prescribes the roles; how you organize it internally is up to you.
Start with clarity, not with a complete system
The most common mistake is not that companies know too little, but that they assume someone else has already taken care of it. A brief internal agreement about who does what prevents most of the problems that arise later.
Do you want to know where your company currently stands and which step deserves attention first? Take the free quick-scan or browse through the topics in the knowledge base to see what is relevant for your situation.