Yes, anyone can technically generate a QR code themselves: there are dozens of free tools that turn a link into a scannable image. What matters for the mattress passport is not the image itself, but what lies behind it: a unique, permanently functioning reference to data that must be current, structurally organized, and accessible for the specified period. That part is considerably more difficult to manage on your own than the QR code itself.
Whether managing it yourself is sufficient in your situation depends on what you already have in place: a stable environment to host data, a way to make changes without breaking old references, and time to maintain this for ten years. For a single mattress model, that is manageable. With multiple models, variants, and repeated changes, it quickly becomes an ongoing task rather than a one-time action.
The difference between a code and a data carrier
The regulation does not only refer to a QR code, but to a data carrier: the means by which someone who scans it reaches the correct, current information. A QR code that simply points to a loose document fulfils the literal action of scanning, but not necessarily what must substantively lie behind it. The precise technical requirements for that carrier, such as the durability of the code on the product itself and the manner in which data must be presented, follow from a delegated act that has not yet been published. Once that text is available, we will add here what specifically changes.
What is already established is the principle: the code must continue to work, even if you change software suppliers, phase out a model, or your factory changes ownership. That is precisely the point where doing it yourself requires extra attention, because a link that works today must still do so in eight years.
What you can reasonably handle yourself
Creating the image, determining where the code appears on the product or labelling, and testing whether it scans properly under normal conditions of use are tasks a company can perform without specialized knowledge. Compiling the source data—that is, the technical and product information that must lie behind the code—also lies with the manufacturer or importer themselves: no one else knows better what is in a specific mattress. In the knowledge bank by subject it is set out which data belongs there and to whom that applies.
What is more difficult to manage yourself
Hosting the data for the specified period, maintaining versions so that older scans do not lead to outdated information, and guaranteeing that the link continues to work even when there are changes in your own IT environment are the areas where doing it yourself often encounters practical difficulties in practice. Not because it is impossible, but because it is a structural responsibility that goes beyond a one-time technical action. A server that runs today must still run in years to come, even if the responsible employee of today is no longer with the company.
Moreover, there is the question of what happens during an inspection. A supervisory authority that scans a code must reach current and correct data. How that process looks in detail and who oversees it varies per member state and is described on the page on how the data becomes a working passport.
Doing it yourself, outsourcing, or a middle way
Many companies opt for a middle way: the substantive data remains their own work, while the technical side, such as hosting and managing the data carrier, is outsourced to a party that has that as a core task. That is not an obligation, but rather a practical consideration between the time it would take to maintain it yourself and the certainty that outsourcing provides.
Whether your situation lends itself to self-management cannot be captured in one general rule; it depends on the number of models, the frequency of changes and the ICT capacity you already have. With a brief scan of your own situation you get a first indication of where you stand, without this being a judgement on what is mandatory for your company.
This page describes the regulation in general terms and is not legal advice on your specific situation. For a judgement on your own company we refer you to a lawyer or to the competent supervisory authority.
Would you like to first calmly see all topics side by side before making a choice? Do the free quick-scan or browse the frequently asked questions about the mattress passport to see which section is most relevant for you.