A mattress product passport is not something you create once and then leave alone. If something changes about the product itself, about the supplier of a raw material, or about the composition of the filling, that change must be reflected in the passport. How much time that takes depends heavily on where the change comes from and how your data is recorded. A small adjustment you can make yourself is often processed the same day. A change that first needs to be requested from a supplier can take weeks.
In practice, the timeframe consists of three phases: identifying that something has changed, gathering the correct data, and implementing the change in the system that feeds the QR data carrier. The first two phases usually take the most time, not the third. Below is an overview of where that process gets held up in practice.
Which changes count
Not every adjustment in your operations affects the passport. New packaging or a different transport supplier usually does not change the product information that the regulation prescribes. A different composition of the mattress core, a changed origin of a material, or an adjustment in the repair and recycling instructions does. The regulation distinguishes between product information that actually concerns the article, and information that only concerns your operations. Only the first category belongs in the passport.
To determine whether a change is relevant, it is helpful to refer back to the data recorded when setting up the passport. If a characteristic is explicitly listed there, then a change in it is relevant. In the knowledge base sorted by subject each data category is explained to show which fields fall under the regulation.
Where the time gets spent in practice
The first delay often occurs when identifying the change itself. A change at a raw material supplier does not always reach the person managing the passport automatically. Companies that have assigned responsibility for the passport to one function, and that function has included it in regular procurement or quality meetings, usually notice changes faster than companies where that happens ad hoc.
The second delay is in gathering evidence. An amendment to the regulation itself requires substantiation, not just a notification. If a supplier only tells you verbally that something has changed, a certificate, test report or supplier declaration often still needs to be requested before the change can be recorded. Requesting this takes the most time in practice, especially with suppliers outside the EU.
The third phase, technically implementing the change, is usually the fastest step. Once the substantiation is in, updating the passport itself is a matter of entering and publishing the data.
What speeds things up and what slows things down
Companies that maintain their product data centrally and in a structured manner usually see changes processed faster than companies that work with separate Excel files or emails. This is also where the conversation with a software supplier becomes relevant: a system that sends a notification as soon as linked data changes saves a lot of time in practice in the first, identifying phase.
Delays arise especially when responsibility for the product passport is not clearly assigned to a single person or team, or when a supplier outside the EU is not accustomed to the type of substantiation that the regulation requires. A QR code that has already been printed on a label can also be a complicating factor: the code itself does not need to change as long as it points to the same underlying page, but the content behind that code must remain up to date.
No fixed deadline in the regulation
The regulation itself does not prescribe a concrete deadline within which a change to the product passport must be processed. What does matter is that the information accessible via the QR code is up to date and traceable at the moment someone consults it. How short the period between change and processing needs to be in practice is for the responsible party to assess, and in case of doubt for the competent supervisory authority or a lawyer to clarify.
To get a picture for your own situation of how your current process scores on these points, you can see where you stand in five questions. Also, an explanation of where the information comes from provides insight into how data flows from supplier to QR code, and which links cost time in this process.
Practical summary
There is no fixed processing time that applies to every company. What is certain is that most time is lost before the actual update: in detecting a change and in collecting substantiation. Companies that have arranged this process in advance experience less delay than companies that only start dealing with it when a customer or buyer asks for it.
If you have questions about a specific situation in your company, consult the official text of the regulation or a lawyer. For an initial, non-binding picture of where your company stands, you can do the free quick-scan or work through the subjects in the answers to questions that other companies also ask.