The QR code on a mattress will soon be more than just a sticker: it is the data carrier that takes a buyer, a supervisor or another link in the chain to the digital product passport. If that code is missing, in practice the access to all the information that the regulation requires for mattresses is missing. The regulation itself distinguishes between the obligation to have a passport and the obligation to make that passport findable on the product. Both belong together, but they are two separate things to arrange.
What exactly happens if the QR code is missing depends on the supervision in the country where the mattress is sold and the phase the regulation is in at that time. Market surveillance authorities generally look at the complete combination during product checks: is there a passport, is the content correct, and is it accessible in the way prescribed. A mattress without working access to the passport can therefore be marked as non-compliant, even if the underlying data exist somewhere.
Why the data carrier is a separate obligation
The passport itself is separate from the product; the QR code is the bridge between them. This means that a manufacturer or importer can in theory have a complete and current passport ready, while the mattress that comes on the market does not carry a readable or working reference. For a supervisor, this distinction is not always visible on a first inspection, but it becomes relevant as soon as someone — a consumer, a test body, another market participant — actually tries to scan the code and encounters a dead link or a blank page.
In the knowledge base, this distinction between passport and data carrier is further elaborated, with the question of which of the two belongs to which party in the chain. For companies that themselves bring mattresses to the market, this is one of the first things to clarify, because the responsibility for applying the code does not automatically lie with the same party as the one that compiles the passport. the explanation per role in the knowledge base makes that distinction clear for each situation.
Consequences that go beyond a fine
It is tempting to think only in terms of sanctions, but a missing or broken QR code also affects the business operations itself. A bedding specialist, for example, who resells mattresses, may have to deal with questions from their own customers who try to scan the code and find nothing. A hotel buyer who purchases mattresses for multiple locations runs the risk that maintenance and replacement are harder to plan without access to the underlying data. These are not legal risks in the strict sense, but practical consequences that undermine the value of the passport as a whole.
The relationship with suppliers and software partners also plays a role here. Anyone who outsources the technical side of the passport should make sure to establish in advance who is responsible for applying, testing and replacing the data carrier on the product itself — not just for filling the passport with data. A short checklist for this helps to conduct this conversation in a structured way, for example on the basis of a short scan that shows where your situation stands on this point.
What is not yet established, and what is
The delegated act that sets out the exact requirements for mattresses under the ESPR has not yet been published; the ESPR work plan names 2028 as the expected period, with implementation around 2030. Concrete deadlines for enforcement, penalty levels or transition periods are therefore not yet fixed. What can already be foreseen is the logic of the system: a product passport without working access defeats its purpose, and this is an omission that can carry both legal and practical weight once the rules are final.
For your own situation — what type of mattress, what sales channel, what role in the supply chain — the official text and the competent supervisory authority remain the designated source; this article describes the system, not an assessment of an individual case. Anyone wishing to see how this distinction is documented in practice will find that in the process behind the mattress product passport.
Start preparing now without waiting for the final date
Even without a fixed date, it is worthwhile to determine now who in your organization will be responsible for applying and keeping the data carrier up to date, and to have that conversation with a software supplier or printer early. Questions that often come up in this regard can be found clearly at the frequently asked questions about the mattress product passport.
Would you like to see where your company currently stands in relation to the obligations that are coming? The free quick-scan provides an initial indication in a few questions, without requiring an account.