Do you need to inform your staff about the mattress passport?
If your company manufactures, imports or sells mattresses, something will change in the work of the people involved: who collects data, who applies the QR code, who answers customer questions. There is no separate legal obligation in the regulation to specifically inform staff about the mattress passport, but the way you organize the work does touch on existing rules concerning information provision and worker participation.
Whether this means something for your company depends on the extent of the change. If it is a small adjustment to an existing work process, ordinary internal communication is usually sufficient. If the way of working changes structurally, for example because a new step is added to the process or new software is used, the usual rules on information provision and worker participation come into play, as they do with other work process changes.
What changes in practice
The passport itself is not a task for the shop floor but a file compiled by the supplier: materials, origin, repair and recycling information. Yet somewhere in the company someone feeds, checks or keeps that file up to date. At a manufacturer this is often someone in production or quality, at an importer someone in purchasing, at a bed specialist store possibly the sales employee who must be able to explain the QR code on the shop floor. Who gets which role is best documented the same way you document other responsibilities. In the knowledge bank by subject is set out which role fits with manufacturer, importer or distributor.
Information provision: what is reasonable to do
Information provision to employees is not a separate obligation under the mattress regulation, but follows from the general duty an employer has to inform staff what is expected of them in a changed work process. In practice this usually means: explaining what the passport is, who creates it, and what an employee should do if a customer asks about it. For most companies this is a matter of brief instruction, not a separate training programme.
Worker participation: when does the works council come into play
The Works Councils Act regulates when a works council has approval rights for changes in the organization of work, for example when introducing new software or a new registration system. Whether the introduction of a system for the mattress passport falls under those rules depends on how far-reaching the change is for employees and the size of your enterprise. This is not a question the mattress regulation answers; those rules already existed and continue to apply alongside the passport. If in doubt, this is a question for your own works council, company lawyer or the GAK desk for worker participation, not for the product legislation itself.
Recruitment: new tasks, rarely a new position
At many companies the introduction of the passport does not lead to a new vacancy, but to an additional task within an existing position: someone in quality or logistics who maintains the file alongside the work they already do. Only at companies that carry many models or supply internationally may the volume of work be a reason to add capacity. This is a business economic decision, not a legal obligation.
What this article is not
This overview describes how the mattress regulation relates to existing rules on information provision and worker participation. It is not advice on your own organization: whether and when the works council has approval rights depends on your specific situation and is for your lawyer, your works council or the trade commission to assess.
Would you like to first see what role your company has in the chain and what obligations come with it, before you determine the internal distribution of tasks? With a few questions you can see where you stand. Are you unsure whether a change is subject to notification to the works council or is more a matter of ordinary work instructions, then look at the most frequently asked questions about the passport in practice, or read at how we compile the passport from your data how much work that entails for your organization.