If you import mattresses from outside the European Union, you typically need more documents than a trader who purchases within the EU. In addition to the data that will eventually go into the digital product passport, these are documents that demonstrate that the product may legally and in accordance cross the border: a technical file from the manufacturer, a declaration of conformity, usually a commercial invoice and transport documents, and information about who acts as a contact point within the EU.
The detail that comes to the fore most on this subject is that as an importer from outside the EU, you often assume a number of responsibilities of the manufacturer at the moment that manufacturer itself is not established in the EU. This changes not only which documents you need, but also who is responsible for ensuring they are correct.
What usually goes into this file
The core of the document package consists of the technical file: the substantiation that the mattress complies with the applicable requirements, with test reports, material information and drawings or specifications. In addition, there is the declaration of conformity, in which the responsible party declares that the product complies with the rules. When importing, commercial documents are added: the invoice, the customs declaration and often a delivery note or transport document on which the country of origin is stated.
What is often forgotten in this specific case is the mention of a contact point within the EU. Supervisory authorities want to know who they need to contact if something goes wrong with a product coming from outside the EU, and in practice that mention should be on or with the product itself, not just in a separate contract.
Why this package is somewhat more extensive when importing from outside the EU
Within the EU, a trader can in many cases rely on the fact that an earlier party in the chain has already drawn up conformity documents. When importing from outside the EU, that premise is different: the manufacturer is outside the jurisdiction where the rules apply, and the importer is often the first party within the EU to receive the product. Supervisory authorities look at who actually acts as the first responsible party, and this is a question that can differ from situation to situation.
For that reason, an importer is typically required to check themselves whether the technical file is present and complete, rather than just storing it without looking at what it contains. That distinction between 'receiving' and 'checking' is precisely the detail that comes to the fore most when importing from outside the EU, and it is also the reason why suppliers are sometimes reluctant to deliver documents all at once: they need to know that the information matches the actual product.
The role of the representative
For mattresses from outside the EU, an EU representative or mandatary is often designated: a party within the EU that acts as a contact point to supervisory authorities. Who that is, and what has been contractually agreed on about who manages which documents, is something that in most cases is agreed in writing between the importer and the manufacturer or intermediary. Without that agreement, it is unclear to both parties who should be able to present which document when a supervisory authority requests it.
How this relates to the digital product passport
The digital product passport is a separate layer alongside this document package, not a replacement for it. The passport contains the product data that will be accessible via QR code to buyers, bed specialty retailers and hotel procurement; the technical file and the declaration of conformity continue to exist as the underlying evidence. In the practice of a company that imports from outside the EU, this means you must have two things in order at the same time: the documents that govern the import itself, and the data that will eventually appear in the passport.
Those who want to see which data are specifically requested for the passport, and which of those are already available from the existing document package, will find an overview by subject in the knowledge base, sorted by situation. That saves double research work when the documents for import and the data for the passport partially overlap.
What this is not
This overview is a description of which documents typically appear in this type of files, not a statement on which documents are mandatory in your specific situation. Whether a product is regarded as import, as import in the sense of the regulations, or otherwise, and who fulfils which role in this regard, depends on the precise circumstances. For that assessment, the official text of the applicable regulation is the starting point, supplemented by advice from a lawyer or enquiry with the competent supervisory authority.
Would you like an indication before you explore this further? With a few questions that immediately provide an indication you quickly see which topics are relevant for your company. Are you still unsure about how the data are collected and stored, then you can read that back on the page showing where the information comes from. And if your question is not among them, there is always an overview of questions that other entrepreneurs also asked.