A hotel that purchases mattresses to place in its own rooms is in most cases an end-user and not a supplier within the meaning of the regulation. The obligations regarding the digital product passport are directed at those who place a mattress on the market or put it into circulation: the manufacturer, the importer, or the person who sells the product under their own name. Those who purchase mattresses purely for use by their own guests or residents do not put the product back into circulation and are therefore generally outside the scope of obligations.
This changes as soon as you offer the mattresses yourself as a product, for example via your own webshop, a hotel shop where guests can buy the bed, or a private-label line under the name of your chain. Also, if you yourself import directly from a country outside the EU, you may fall under the obligations that normally rest with the importer. The boundary therefore does not lie in whether you purchase mattresses, but in whether you then place them back on the market as an independent product.
When you become a supplier and when you do not
The regulation distinguishes roles based on what a business actually does, not based on the sector in which it operates. A hotel chain that purchases mattresses from an established manufacturer and uses them exclusively in its own rooms acts as an end-user of that product. The obligation to have a passport drawn up and maintained then rests with the party that made or imported the product, not with the hotel.
The situation changes when a business passes the product on to a third party as an independent offering. Think of a holiday park that rents or sells mattresses separately to guests, a care facility that supplies mattresses to an affiliated foundation, or a chain that has mattresses manufactured under its own brand name. In such cases, a business can itself assume the role of manufacturer, importer or distributor, with the associated obligations. Read more about how those roles are precisely defined in the knowledge base with explanations per role and situation.
Practical examples from hotel and care sectors
A mid-sized hotel that orders mattresses from a Dutch wholesaler for its own rooms is generally not a supplier: it uses the product, it does not resell it. A franchise chain that has mattresses manufactured under its own brand name and supplies them to all branches can be classified as a manufacturer or importer, even if the mattresses are only used internally and not sold separately to consumers. A care facility that resells mattresses to residents who are setting up independently is doing something other than merely using them and may therefore fall into a different role.
Because these boundaries depend on the precise design, business structure and contracts, it is not possible to say in general terms that a particular type of organization always does or does not fall under the obligations. For your specific situation, it is advisable to consult the official text or to ask a lawyer or the competent supervisory authority how a specific purchase or sales arrangement will be assessed.
What this means for your purchasing, even without your own obligation
Even if your company is not a provider itself, the product passport is relevant for your purchasing decision. The passport of a mattress shows which materials have been used, how repair and recycling are arranged and who is responsible for the data. For hotel procurement with a view to sustainability goals or a quality mark, this is often useful information, regardless of whether you need to have one drawn up yourself. When drafting purchasing contracts, it is therefore advisable to lay down who supplies and maintains the passport, especially for larger volumes or private label. For specific questions on this matter, you can the most frequently asked questions about the passport in practice go through.
Check your own position quickly
Because role and obligation depend on exactly what your company does with a mattress after purchase, a short self-check is often faster than an extensive legal investigation. With a few questions you will immediately see an indication of your situation and, if you want to know what that indication is based on, that is explained on the page on how the information is produced.
If you have doubts about your own position in the supply chain, that ultimately remains a question for a lawyer or the competent supervisory authority. If you want to get an impression yourself first, do the free quick-scan or browse through the topics in the knowledge base.