Yes, as a company you can prepare part of the technical documentation for the mattress passport yourself, provided you have the right source data. This concerns information you as a manufacturer or importer should already have in-house: material composition, origin of raw materials, test reports and maintenance instructions. The regulation does not prescribe who collects or enters that data, only that it must be correct, complete and accessible for ten years.
Where things often stall is not the collection itself but structuring that data correctly and linking it to a passport that meets the technical requirements. This is the point at which companies weigh up doing it themselves versus outsourcing, and that assessment is different for an installation company with one mattress model than for a manufacturer with dozens of variants.
What should be included in the technical documentation?
The technical documentation behind a mattress passport typically consists of a number of fixed components: a description of the materials used, data on origin and recyclability, results of safety and fire tests, and instructions for maintenance and end of life. Some of that data you already have because you also need it for other regulations, such as product safety. Other data, such as a structured link to the data fields prescribed by the regulation, often still needs to be built.
What can you realistically do yourself?
In practice, collecting source data is closest to what a company can do itself, simply because no one knows that information better than you or your supplier. Keeping data up to date after a change in material or composition is also something that can be well managed internally, provided one person or department is designated to maintain it. the knowledge bank with worked-out topics per situation indicates at each step which data are usually needed, so that you can prepare for that internally before you outsource anything or proceed further yourself.
What is more difficult to do yourself is converting that data into a passport that technically meets the requirements and is linked to a QR data carrier that works for ten years. This requires knowledge of the data structure that the regulation will then require, and that knowledge changes as soon as the delegated act is published.
Where does the boundary with outsourcing lie?
The boundary usually does not lie with collecting data, but with three things: the technical formatting of the passport, hosting it for the mandatory period, and ensuring that the QR code continues to work even if your company switches software providers or discontinues a product line. These are components for which specialized parties exist, precisely because an error in this only becomes visible years later, when a customer or supervisor scans the QR code and finds nothing usable behind it.
A practical rule of thumb that many companies follow: everything to do with the content of your own product, you keep under your own control. Everything to do with the technical maintenance of the passport over the years is more often outsourced. how the data are collected and processed into a working passport shows which steps are involved and who normally takes responsibility for which part.
What remains your responsibility, even if you outsource?
Even when you outsource the technical processing, responsibility for the accuracy of the underlying data remains with your company, not with the party that hosts or compiles the passport. This means that a service provider can never relieve you of the obligation to know what is in your mattress and where that data comes from. Outsourcing thus shifts the technical work, not the substantive responsibility.
How do you recognise whether you are ready for it yourself?
Whether doing it yourself is feasible depends largely on the number of models you offer, how often compositions change, and whether you already use software that can provide data in a structured format. A company with one stable mattress model is in a different position than a manufacturer that introduces new variants every year. To make an initial assessment of your own situation, you can see in a few questions where your company currently stands, without this immediately creating an obligation.
Should you still have doubts or questions about your specific situation after reading this, it is advisable to put them to a lawyer or the competent supervisory authority. For general questions about how other companies approach this, the overview with frequently asked questions often already provides a first direction.
Do you want to explore yourself whether and how the mattress passport will apply to your company, and what of that is feasible for you to do yourself? Take the free quick-scan or read through the other topics in the knowledge bank, so that you know with confidence where you stand.