Anyone selling mattresses in multiple EU countries often wonders whether the digital product passport will be checked the same way everywhere. The answer is nuanced: the regulation itself is an EU regulation and therefore applies directly in every Member State, without a country needing to first transpose it into its own legislation. The core of the obligation, such as which information belongs in the passport and that a QR data carrier must be attached to the product, is thus the same in Rome as in Rotterdam.
What can differ per country is the way market surveillance is organised. Each Member State appoints its own market surveillance authority, with its own procedures, its own priorities and its own language. Practical matters too, such as the language in which the passport must be readable for the end user, can vary per country. This is not a contradiction in the rules, but a consequence of how market surveillance is organised in the EU: the standard is European, the implementation is national.
What remains the same at EU level
The substantive requirements for the passport, such as which materials, maintenance instructions or sustainability data must be included, follow from the regulation and the delegated act for mattresses. These requirements apply to any economic operator placing the product on the market in the EU, regardless of which country this takes place in. The concept of the QR data carrier as access to the passport is also an EU-wide agreement, not something that is reinvented per country. For those wondering what an economic operator precisely means and what role comes with it, that is a separate subject covered in the knowledge base with explanations per situation .
What can differ per country
Market surveillance itself is the responsibility of national market surveillance authorities. In the Netherlands this is usually a different body than in, for example, Germany or France, with its own contact points and its own inspection methods. In addition, the language in which the passport must be accessible can depend on the country where the product is sold: a passport that is sufficient in the Netherlands with Dutch-language information may also need to be available in French or German when the product is marketed there. Finally, Member States can, within the framework of the regulation, set their own additional rules on enforcement, for example on how a breach is established or what steps a market surveillance authority takes. For companies operating internationally, this makes it wise not only to look at the European text, but also to check what the market surveillance authority in the country of destination has to say about it.
Why this is especially relevant for cross-border sales
For a business selling exclusively in the Netherlands, this distinction is mainly background information. For anyone supplying mattresses to hotels or specialist retailers in multiple countries, it becomes more practical: the same mattress can cross the border in one country with exactly the same passport data, while in another country an additional language or a slightly different delivery method may be expected. This is no cause for concern, but it is something to check in advance with the competent market surveillance authority of the country where the product is marketed, or with a lawyer who works with cross-border regulations.
Because the delegated act for mattresses has not yet been published, it is also not yet clear how detailed these country-specific differences will be filled in. As soon as the text is available, this page will be updated with what changes in concrete terms. Until then, it is mainly useful to know that the basis is European, and the implementation is coloured nationally.
Would you like to see in advance how your own situation looks, regardless of which countries you supply? a few questions will give you an immediate indication where you stand, and in the frequently asked questions about the product passport you will find more information about how supervision and enforcement work in practice. Curious about how we collect the data for the product passport and where it comes from? You can read about that on the page on how matrapas.eu compiles the information.