A digital product passport for a mattress is not a document that you draw up once and then set aside. It is a file that must remain accessible throughout the entire lifespan of the mattress, and that means the data in it can become outdated: a supplier changes material, a certificate expires and is renewed, or a company name changes after a merger. What exactly happens if you do not implement such a change depends on the type of data and who is looking at the passport at that time.
The shortest answer is this: an outdated passport is a passport that no longer matches reality, and that can play a role in two ways. First, a competent authority may find during an inspection that the information does not correspond to the product as it actually is on the market. Second, a business customer, for example a hotel purchaser or a bed specialist retailer, may doubt the reliability of the rest of your data if one part turns out to be outdated. Both situations can be made descriptive, but we cannot make a statement here on how strictly that will be assessed in practice.
What data typically changes
In practice, we see a few recurring categories. Material composition changes when a manufacturer switches foam or filling, for example to comply with stricter fire safety requirements. Certificates and test reports have a validity period and are renewed periodically. And company data, such as the name of the supplier or the address of the responsible party, change in the event of takeovers or relocations. Who is in the chain and thus which data falls under his responsibility is a question that is answered separately in the knowledge base with explanations per role in the chain.
Who notices something
A mattress passport is not checked daily, but it is permanently accessible via the QR code on the product. This means that three parties can consult it at a time of your choosing: a competent authority during a market surveillance activity, a business customer conducting due diligence for a large order, and in some cases the consumer himself. How supervision is organised in the Netherlands and other EU Member States varies from country to country and is explained in other articles on this platform. For your own situation, the competent authority remains the appropriate party to ask what is happening in a specific case.
The difference between not updating and making errors
It is good to distinguish between two situations that are often confused. The first is that data simply becomes outdated because no one has updated it after a change in the product or the company. The second is that an error has already crept in when the data was entered, for example an incorrectly entered certificate number. Both result in a passport that does not match, but the cause and thus also the way you remedy it differs. A process in which changes are systematically communicated to those who manage the passport prevents the first situation; a second check before publication prevents the second.
How long a passport must remain up to date
The obligation to host the passport runs for a period of ten years, and throughout that entire period the information in it must reflect the current situation. This is a longer horizon than most companies are used to for product documentation, and it is one of the reasons why companies often outsource this aspect rather than manage it themselves. How such outsourcing works in practice and what agreements you make with a supplier about it can be read in the explanation of where the information comes from.
What you can practically do with it
A concrete working process helps more than figuring out afterwards what went wrong. Think of a fixed point of contact within your company who flags changes in materials, certificates or business information, and a short line to whoever actually updates the passport. For companies that do not yet know where they stand in this process, the free quick-scan with a few questions an initial indication, without any obligation attached to it.
This page describes general points of attention and is not legal advice on your specific situation. For an assessment of what applies in your case, a lawyer or the competent supervisory authority is the appropriate route. If you are unsure where to practically begin, please check the frequently asked questions about the mattress passport or take the quick-scan to see which topics are relevant for your company.