Short answer
CE marking and a digital product passport are two different things that do not automatically coincide. CE marking applies to product categories for which a harmonised EU directive or regulation sets technical requirements, such as machinery, toys or construction products. Mattresses generally do not fall under such a directive, unless a specific component — for example an electric adjustable mechanism in a box spring — falls under a separate regulation that does require it.
The digital product passport comes from a different framework, the ecodesign regulation (ESPR), and concerns information: materials, origin, repair options and end-of-life data. It is not a safety mark and therefore does not replace CE marking, and the same applies in reverse. Those who confuse the two concepts risk collecting the wrong documentation or omitting the wrong steps.
Why mattresses usually do not have CE marking
CE marking is linked to a list of EU directives that prescribe technical requirements and conformity assessment per product group. For mattresses as such, such a specific directive does not usually exist. This does not mean that a mattress may be placed on the market without rules: the General Product Safety Regulation (GPSR) continues to apply and sets general safety requirements for products that do not fall under a specific directive. In addition, fire safety standards, chemical substance restrictions (such as REACH) and national requirements may play a role, depending on the country where the mattress is sold.
Whether a specific product, or a component of it, actually falls under a CE-required directive must be assessed on a case-by-case basis. An electrically adjustable bed base frame, for example, may fall under the low voltage directive, while the mattress itself does not. For that assessment, the official text of the relevant directive is the starting point, and in case of doubt, a lawyer or the competent supervisory authority is the right party to confirm it.
How the passport relates to this
The digital product passport is separate from this safety assessment. The passport collects and discloses information required by the regulation, for example on material composition and circularity, and makes it accessible via a QR code to those who need it: supervisory authorities, recyclers, and sometimes the consumer. A manufacturer who has their CE file in order does not need to process that file into a product passport, and conversely, a complete passport does not provide CE compliance.
In practice, this means that a company can run two separate processes: one focused on product safety and possible CE compliance, the other on the information obligations of the passport. Both processes require the same source data, such as material lists and supplier declarations, so it is practical to record that data once properly and use it for both purposes. Those who still need to find out which data exactly that is, will find in the knowledge base with explanations per topic an overview of what the regulation requires per obligation.
What this means for your administration
Because CE marking and the digital product passport serve different purposes, it is advisable to administer them separately as well: one file for product safety with test reports and declarations of conformity, and one file for the passport with material and origin data. Overlap between the two files is normal, but one does not replace the other. Supervisory authorities reviewing the passport look at different aspects than a market surveillance authority assessing product safety, and moreover this differs per Member State in the way it is organized.
For companies that want to see where their mattress model currently stands in relation to both frameworks, the questionnaire that provides an indication in a few steps a low-threshold starting point. The outcome is an initial direction, not a final assessment — for a concrete evaluation of a specific product, a lawyer or the competent supervisory authority remains the appropriate route.
Learn more about the source of this information
Because this topic touches on multiple regulations at the same time, it is useful to know where the information on matrapas.eu comes from and how it is kept up to date. That is explained on the page that explains where our information comes from. If you still have doubts about your own situation after reading, the next step is usually not to read more, but to ask a targeted question to a lawyer or the competent supervisory authority.
If you first want to get an idea for yourself without immediately committing to anything, then go through the free quick-scan or browse through the other topics in the frequently asked questions about the mattress product passport. Both are a good starting point to see which part of this subject is relevant to your company.