If you sell mattresses under your own brand name, while another company manufactures them for you, you will in most cases need more documents for the digital product passport than a manufacturer who sells only under its own name. In addition to the usual material and composition data, this concerns the technical documentation of the original producer, a binding agreement on which party supplies which data, and proof of where in the supply chain the responsibility for the passport lies exactly.
The reason is that the regulation does not ask who actually makes the product, but who places it on the market under his name. If you put your own brand on a mattress manufactured elsewhere, you may thereby assume the role that the regulation assigns to a manufacturer, with the associated obligations for the passport. That is precisely the detail most often overlooked in private label sales.
The list of documents you need
For a private label mattress, it is usually the same basis as for any product passport: material composition, origin of raw materials, data on repair and disassembly, and information on recyclability. A private label adds a written confirmation from the original producer that this data is correct, and an overview of which party in the supply chain has supplied which part of the information. Without that overview, it is difficult later to demonstrate where a piece of data comes from, and traceability is precisely a core point of the passport.
Anyone working this out for the first time often finds that their own records contain the sales data but not the underlying technical documents from the producer. These must be requested separately, preferably before a product line is already on the market.
Setting out agreements with your producer
Because responsibility for the passport can shift to whoever manages the brand, for private label sales it is advisable to set out in the purchase contract who supplies which data, in which language and in which format. This prevents a mattress from already being on the shelf while the technical substantiation is still sitting on the producer's shelf. For companies arranging this for the first time, the knowledge base with explanations for each situation provides an overview of which agreements go with which role.
What if the producer is outside the EU
For mattresses manufactured outside the EU and sold under a European private label, the same detail plays an even more prominent role: the party managing the brand is often the one a supervisor will contact if data is missing or unclear. This does not automatically mean you alone are responsible, but it does mean it is advisable to clarify in advance which documents you have in your possession and which remain with the producer. For your own situation, this is something to discuss with a lawyer or with the competent supervisor; this article only describes what distinction the regulation makes.
Where this data comes together
The digital product passport itself is not yet mandatory: the delegated act for mattresses is expected to be published in 2028, with an obligation taking effect thereafter, presumably around 2030. That date is not yet fixed and will be updated here as soon as the act is published. That is the moment when the documents mentioned above together form the passport that becomes accessible via a QR code. Anyone who already wants to see how such a collection of data leads to a passport can read how we collect and process the data.
Because the precise list differs depending on the business situation, and private label sales is one of the cases where the division of roles matters most, many entrepreneurs find it helpful to first briefly determine their own position before requesting documents. This saves back-and-forth with a producer who may turn out not to have the right documents after all.
Do you want to quickly know which situation applies to your business, then you can have that shown in a few questions with a direct indication. For broader background on roles, deadlines and the status of affairs per subject the overview with frequently asked questions provides a good starting point.