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Must the mattress passport be in the language of the country if you sell abroad?

If you sell mattresses in multiple EU countries, the question arises of which language the data in the passport must be available in. This article explains why this can currently differ per member state and what that means for the design of your passport.

Short answer

The regulation governing the digital product passport for mattresses prescribes one uniform data carrier: the QR code. The code itself is language-independent, but the data it refers to is not necessarily so. Whether that data must be available in Dutch, German, French or another language depends not only on the delegated act for mattresses yet to be published, but also on existing rules that already provide guidance on language vis-à-vis the consumer in each member state.

At this time, no delegated act has been published that sets out the precise language requirements for the mattress passport. The European Commission's work plan mentions 2028 as the expected time for this, with a passport expected to become active in practice around 2030. Both dates are not yet fixed. What has already been in place for longer is that member states can determine through existing consumer law and product safety rules that information for the end user must be in a language that the user understands.

Why language is a matter for the member state, not just Brussels

The General Product Safety Regulation and related EU rules generally leave room for individual member states on the issue of language. A manufacturer placing mattresses on the German market may face a requirement that instructions for use and safety warnings be available in German, while the same mattress in the Netherlands may suffice with Dutch or English language information. This difference exists independently of the digital product passport and is therefore not something new being introduced by the ESPR; rather, it is a given that the passport must take into account once it becomes operational.

The supervisory authority in each country looks at what can reasonably be expected of a consumer or professional purchaser in that country. For a hotel chain purchasing mattresses through a Dutch distributor but with premises in multiple countries, this may mean that the same mattress is offered with different language versions of the same underlying data, depending on where the product is ultimately used.

What this practically means for the content behind the QR code

Because the passport behind the QR code consists of structured data, this does not necessarily mean you need a completely separate passport for each country. It is mainly a question of whether the display of the same data can be shown in multiple languages to whoever scans the code. This is a technical and organizational question, not a substantive change to the data itself. For companies selecting software now, this is one of the points worth discussing early. how the data in the passport is created gives an overview of which sources are used and where translation fits in that process.

The delegated act for mattresses may, once it appears, explicitly set out in which language or languages the passport must be available at minimum within the EU. Until that text is published, that cannot be said with certainty, and any statement on it in advance would go further than what is currently known.

What you can already consider

For companies that export mattresses or sell across multiple EU countries, it is useful to map out which countries your products actually reach and what language requirements currently apply in those countries for instructions for use, labels and safety information. This inventory is separate from the product passport itself, but it does provide the basis for setting up a passport more easily later. A conversation with your software supplier about whether the system supports multilingual display prevents this from having to be built as a separate addition later.

Because the rules in this area differ by country and can vary by situation, translating this general guideline to your own assortment and sales markets is something on which a lawyer or the competent supervisory authority in the country in question can provide definitive advice. In the knowledge base, tailored per situation there is an overview of the subjects related to this, each with the source in the official text.

Would you like to first clarify for yourself where your company currently stands with respect to the upcoming product passport? With a few questions you get an indication of what is relevant for you, and on the frequently asked questions page you will find answers to similar practical questions. The quick scan is free and requires no account.

This article is general information and not legal advice.