Whether the digital product passport for mattresses applies to your company depends first and foremost on your role in the supply chain. The regulation places the obligation primarily on whoever places a mattress on the European market: the manufacturer or the importer. Those who only resell, lease or use mattresses, such as a bed specialty store or a hotel, often encounter it in practice because the passport has already been provided by the party that made or imported the product.
A second factor also plays a role: the precise moment when this obligation comes into effect is not yet fixed. The delegated act that regulates this for mattresses has not yet been published. The European Commission's work plan for 2025-2030 does mention mattresses as a product group for which such an act is being prepared, with 2028 as a target date for publication. Until that text is available, no one can say with certainty from which date and for which mattresses exactly a passport becomes mandatory.
Who typically comes into the picture
The regulation works with a number of roles that determine who has which obligation: the manufacturer, the importer and the distributor are the best known. A company that has mattresses produced and sells them under its own brand name is generally considered to be the party responsible for the passport for those products, even if the physical production takes place elsewhere. The same applies to a company that imports mattresses from outside the EU to sell them here. What these roles precisely entail and where the boundaries lie is explained in the definitions of manufacturer, importer and distributor set out.
Who usually falls outside, and where the nuance lies
An installation company that installs mattresses in a care project, an office organization that purchases a few mattresses for a staff room, or a hotel that orders mattresses from a wholesaler: in most cases the obligation to compile the passport lies with the supplier, not with the customer. However, that is not a free pass to do nothing about it. Whoever makes purchases can face questions about origin and composition that are answered through the passport, for example in hotel procurement where sustainability requirements are part of the tender. And a distributor has, even without producing anything themselves, their own responsibility to check that a passport is present before a product is resold.
If you run your own brand or have it custom-made
The situation changes as soon as a company places mattresses on the market under its own name, even if production is outsourced. Think of a bed specialty store with its own house brand, or a hotel chain that has mattresses made to its own specifications. In such cases it is worth investigating early under which role the regulation will likely place the company, precisely because that determines who must have the passport compiled and who is the point of contact for it. You can get an initial impression of this with a few questions that show where your company probably stands.
What is already worthwhile to do now
Even without the definitive date being known, it is useful to now map out which mattresses your company itself places on the market, which you only resell, and which suppliers you obtain them from. This inventory takes little time and prevents you from having to start from scratch later, once the delegated act is there. How we keep track of where information comes from and when it was last updated is explained on the page about the source of our information.
What still needs to follow
Once the delegated act for mattresses has been published, the date and precise scope will be updated here. Until then, it is advisable, if you are uncertain about your own situation, to consult the official text or contact the competent supervisory authority or a lawyer, especially if your company operates its own brand or imports mattresses from outside the EU.
Would you like an initial, non-binding assessment of where your company stands in this chain? The free quick-scan provides an indication in a few questions, and the knowledge bank brings together the topics that are most relevant for SMEs in the mattress industry.