Does the General Product Safety Regulation apply to your business? The short answer: probably yes, if you sell or supply mattresses to consumers within the EU, whether as a manufacturer, importer, distributor or via a web shop. The regulation applies to virtually all products offered to consumers, and a mattress simply falls under that. These rules are separate from the future digital product passport and are already applicable now.
For those who supply exclusively to other businesses, for example a manufacturer who only sells to wholesalers or other companies, the situation is different. The regulation is aimed at consumer protection; purely commercial supplies do not automatically fall under the same obligations. Below you can read where that line is roughly drawn and what questions you can ask yourself about it.
What the General Product Safety Regulation regulates
The General Product Safety Regulation, also referred to by the English acronym GPSR, is an EU regulation that has been applicable since 13 December 2024. It replaced the older general product safety directive and sets requirements for the safety of products offered to consumers, regardless of whether this is via a physical store, a web shop or an online marketplace. In doing so, the regulation distinguishes roles that are comparable to what you know from the product passport: manufacturer, importer and distributor, each with their own responsibilities such as risk assessment, technical documentation, product traceability and a contact point where complaints or notifications are received.
When the regulation applies to your business
The regulation comes into play as soon as your product, in this case a mattress, reaches a consumer. This applies to a manufacturer who sells directly to private individuals, to a bed specialty shop that supplies mattresses to customers, and to a web shop or marketplace that offers mattresses via distance selling. Also, if you import mattresses from outside the EU and then place them on the European market, you may fall under the regulation as an importer. In the knowledge base with explanations for each situation you can find more about how these roles relate to the roles used by the mattress regulation itself.
When this is less or not relevant
In the case of purely commercial supplies, the situation is different. A producer of mattress foam or components that supplies exclusively to other manufacturers does not address itself directly to the consumer and therefore does not automatically fall under the same obligations as a selling party. Nevertheless, caution is in order: as soon as the end product reaches a consumer via the chain, the question may arise as to who is responsible for what. Supervisory authorities look at the actual role in the chain, not just the name on the invoice.
How this relates to the mattress digital product passport
A frequently asked question is whether the General Product Safety Regulation will be replaced once the digital mattress digital product passport becomes mandatory. This is not the case. The product safety regulation already exists now and is about the safety of the product itself. The digital product passport, which follows from the ecodesign regulation and is expected to become mandatory around 2030, is about information: materials, origin, repair and end of life. Both regulations will then exist side by side and ask for different data, collected at different times in the process. Anyone who now checks what data is available and where it comes from can use that work for both obligations. In the explanation of how we process data you can read what such a preparation looks like in practice.
What you can concretely check
To determine whether the regulation applies to your company, it helps to clarify three things: who acts as manufacturer, importer or distributor in your supply chain, whether your mattresses reach consumers or remain exclusively with other businesses, and whether your current documentation already provides a point of contact for complaints and reports. For assessing your own situation, the text of the regulation itself is authoritative, supplemented by what the product safety supervisor publishes on the subject; in the Netherlands, that is the NVWA. In case of doubt, a lawyer is the appropriate party to assess this for your specific company.
Do you first want to clarify where you stand with the mattress passport, independently of these product safety rules? With the free quick-scan of a few questions you get an immediate indication, and in the overview with frequently asked questions you will find answers to the questions that other companies have already asked.