A manufacturer, an importer and a distributor are three different roles in mattress regulation, and those roles determine which obligation each party bears. In short: the manufacturer is the party that designs or has the mattress produced and places it on the market under its own name, the importer brings a mattress from outside the EU onto the European market for the first time, and the distributor sells a mattress further without making any changes to it themselves.
This distinction is more than just a matter of definitions. The obligation to compile a digital product passport rests primarily with the manufacturer. An importer and a distributor have other, usually lighter obligations, unless they themselves carry out actions that place them in the position of manufacturer. Which role applies to your business depends on what you actually do with the mattress, not on what you call yourself.
Who is the manufacturer of a mattress?
The manufacturer is the party that designs the mattress, has it produced, and places it on the market under its own name or brand. This need not be the party that physically stitches or fills the mattress. A company that has a mattress produced by a factory in the EU or abroad, but sells it under its own brand name, is generally regarded as a manufacturer. This is an important point for bed specialists and hotel chains that work with their own house brands: the label partly determines who is responsible, not just the place of production.
What does an importer do, and when do you count as an importer?
The importer is the party that brings a mattress from outside the European Union onto the European market for the first time. Anyone who purchases mattresses from a manufacturer outside the EU and subsequently sells them in the Netherlands or elsewhere in the EU fulfils this role. The importer must ensure, among other things, that the manufacturer has met its obligations, and thus has a supervisory role, rather than building the passport from scratch themselves. For companies that source mattresses directly from a country outside the EU, this is often the first point at which the question "what is my role" becomes concrete.
The role of the distributor
The distributor stands further down the supply chain: a wholesaler, a bed specialist or an online shop that resells mattresses without modifying them or putting them under its own name. A distributor must verify that the required passport and the associated QR data carrier are present before offering a mattress for sale, but does not need to draw up that passport itself.
When a distributor can be regarded as a manufacturer
The detail where it often gets tangled in practice: as soon as a distributor makes a change to the mattress, or places it on the market under its own brand name, that party can still be classified as a manufacturer. This happens for example when a bed specialist has a mattress re-packaged and given its own label. The actual action counts, not the name a company gives itself. For those in doubt about whether a modification is significant enough to cross this threshold, this is typically a question for a lawyer or for the supervisory authority responsible for the mattress regulation.
Why this classification matters for the mattress passport
The classification into manufacturer, importer and distributor fundamentally determines who supplies the data for the passport, who checks it, and who can be held accountable if something is missing. For a company that only resells mattresses, the emphasis is on checking and retaining what has been provided. For a company that places mattresses on the market under its own name, the emphasis is on providing complete and accurate data. In the knowledge base with explanations for each situation the different roles are further elaborated, including the location in the official text.
What this means for your company
Because your company's role depends on exactly what you do with a mattress, it makes sense to clarify that first before discussing the passport with a supplier or software partner. Anyone uncertain whether they act as a manufacturer, importer or distributor can get a first indication in a few questions of where your company likely stands. This is a starting point, not a legal judgment on your own situation; for a definitive assessment, the competent supervisory authority or a lawyer remains the appropriate contact.
It is also useful to know where the data for the passport comes from and who is allowed to provide it, especially if multiple parties in the chain are involved. An overview of where the information comes from shows how that process works in practice. And for anyone who still has questions after reading this article about specific situations, such as own brand, mixed production or resale within a group of companies, the overview with frequently asked questions often already provides a first answer.
Would you like to know where your company fits in this classification? Take the free quick-scan or browse through the topics in the knowledge base to see which obligation corresponds to which role.