Who is the supplier?
In European product legislation, and soon also in the regulation that makes the digital product passport for mattresses mandatory, the chain is divided into roles. The manufacturer makes the mattress. The importer brings a mattress from outside the EU onto the European market. The distributor supplies the mattress further, without changing anything about it. The term 'supplier' is used for the party that actually makes the mattress available to the end user: the customer in the shop, the hotel chain that is purchasing, or the company that rents out mattresses. This can be the manufacturer itself, but in practice it is often the bed specialist shop or the wholesaler that forms the final part of the chain.
The distinction is not merely linguistic. Each role in the chain receives different obligations under the regulations. A manufacturer compiles the technical data that go into the passport. A supplier must ensure in practice that the QR code with that data belongs to the product at the moment the customer receives the mattress. Who fulfils which role therefore determines who does which part of the work, and who must be able to provide which information if asked to do so.
Why this distinction matters to you
For most entrepreneurs in this sector, the question is not abstract. An installation company that supplies mattresses as part of a hotel renovation, an office manager who purchases beds for staff accommodation, or a bed specialist shop that has mattresses produced under its own name: they can all end up in a different role than they expect. Anyone who puts a mattress on the market under their own brand name is generally no longer seen as an ordinary distributor but as someone closer to the manufacturer role. That changes what is expected of you when compiling and making the passport available.
It is therefore useful to clarify with each supplier who fulfils which role in the chain, and not to assume this based on how the relationship has always been. A wholesaler that only resold in the past can suddenly have different responsibilities under private label. read the concepts per role carefully provides an overview of how the different roles in the chain relate to each other, with the practical implications worked out per situation.
The practice: private label and intermediary trade
The detail where this question often gets stuck in practice is precisely this: private label. A mattress manufacturer produces, but a retail chain or hotel group puts their own brand name on it and sells it as their own product. In that case, responsibility shifts in part towards the party that holds the brand, even if that party has not changed anything about the mattress itself. That is a different starting point than with ordinary resale, where the manufacturer or importer supplies the data and the retailer only sells.
For companies that sell both their own brands and brands of others, this means the role can differ per product line. That is not a matter of setting things up right or wrong, but of precisely establishing who does what, so that there is no gap between manufacturer, importer and supplier. When setting up a passport, this is usually the first point discussed with a software supplier or platform such as matrapas.eu: which party supplies the data, and which party is responsible for keeping it available to the customer. how that data reaches us and is processed describes that process step by step.
What is not yet established
The precise definitions and obligations for mattresses follow from a delegated act under the ESPR, which according to the current work plan of the European Commission is expected in 2028. As long as that text has not been published, no one can say with certainty how each detail of the concept of 'supplier' for mattresses will be filled in precisely. For the exact, current wording, the official text on EUR-Lex is and remains the source, and for questions about your own position in the chain, a lawyer or the competent supervisory authority is the right point of contact.
Would you like to get a first impression for your own business of where you stand in the chain and what that means for the product passport? With a few questions you immediately see an indication, or browse through the answers to questions that other entrepreneurs also ask.