If you also sell mattresses in Germany, France or Belgium, the first question is usually: does the digital product passport need to look different there? The answer is nuanced. The ESPR is a European regulation, and a regulation applies directly and in the same way in all Member States — unlike a directive, which must first be transposed into national legislation and can therefore differ from country to country. The content that the regulation prescribes for the mattress passport therefore does not change because you cross the border.
What can differ is not in the regulation itself but in the context surrounding it: the language in which information must be available, which supervisory authority in that country carries out checks, and whether, in addition to the ESPR, national rules apply that have nothing to do with the passport but exist alongside it. For an SME selling across borders, these are the points to keep in focus.
One regulation, but not the same implementation everywhere
Because the ESPR applies directly, no Member State needs to create its own law to introduce the obligation for a digital product passport. That is precisely why a mattress manufacturer in the Netherlands will soon have to record the same basic data as a manufacturer in Spain or Poland. However, implementation and enforcement are the responsibility of the Member States themselves. Each country appoints its own market surveillance authority, and these authorities do not always work in identical ways. One authority checks, for example, mainly at import at the border, another through spot checks at points of sale. For your company, this means above all that you cannot automatically assume that an inquiry from a supervisory authority abroad will proceed in the same way as you would expect in the Netherlands.
In addition, the regulation stipulates that certain information must be available and comprehensible to the user. In practice, language plays a role here: a hotel chain that procures mattresses for locations in several countries would do well to check whether the information in the passport is also readable for staff or the supervisory authority in that country. In the knowledge bank by subject you will find the background to this type of question, investigated per situation rather than in general terms.
National rules that exist independently of the passport
In addition to the ESPR, a number of Member States have rules that have nothing to do with the digital product passport, but which may apply to mattresses. Think of fire safety requirements for mattresses in the hotel industry, which in some countries are stricter or differently structured than in the Netherlands. Think also of waste legislation: different Member States have their own systems for the collection and recycling of mattresses, set up independently of each other and with their own obligations for producers or importers. These rules do not fall under the ESPR and are not replaced by it. They exist alongside it, and whether they apply to your company depends on the country where you sell or export.
This is precisely why it is unwise to assume that a passport that is complete in the Netherlands is automatically complete for every other EU country. The basic obligation is the same, the environment around it is not necessarily.
Sales outside the European Union
If you also sell outside the EU, the picture changes once more. The ESPR is European legislation and applies only within the EU and the European Economic Area. For exports to a country outside that zone, the requirements of that country apply, not the ESPR. Conversely: if you import mattresses from a country outside the EU to bring them to the European market, the party doing so is usually considered the party responsible for placing them on the market, with the associated obligations regarding the product passport. Which role exactly applies to your company in the case of import or export varies from situation to situation, and for this the official text and, in case of doubt, a lawyer or the competent authority are the appropriate route.
What this means for your company
If you sell within the Netherlands, the question of country differences is less pressing. If you also sell across borders, it is worthwhile to briefly check for each country where you are active: which competent authority is responsible there, is there a language requirement, and are there additional national rules on fire safety or waste management that apply alongside the product passport. This is not legal homework for the long term, but rather something to routinely consider when you are evaluating a new sales market.
On the frequently asked questions page are the questions that other manufacturers and buyers have already asked about cross-border sales, with a brief answer and the reference to the official text. And if you want to know what your own situation looks like before you delve into details, the free quick-scan with a few questions provides an initial indication, even without you needing an account for it.
Do you first want to understand how we obtain the information on this site and why the source citation is deliberately freely accessible? That is explained on the page about how matrapas.eu works. If you still have doubts after reading whether your situation requires something special, the quick-scan is a low-threshold first step, and for the legal explanation of your specific case, a lawyer or the competent authority remains the appropriate route.