If you rent mattresses to hotels, care facilities or event locations, you essentially need the same documents as for sales: the digital product passport itself, the underlying technical documentation, and where applicable a declaration of conformity that belongs with product safety rules. The difference is not in the list, but in who keeps those documents current as long as the same physical mattress ends up with different users year after year.
Concretely, this concerns the following documents: the data that the manufacturer or importer has provided about material and composition, the passport itself with the QR data carrier that remains attached to the mattress, a record of any cleaning, repair or refurbishment between two rental periods, and the agreement with the party hosting the passport about who may make changes. With sales, the mattress changes owner and the documentation obligation is largely complete at the moment of delivery. With rental you remain the party responsible for the product as the lessor, even after it has been lent out ten times.
Why rental adds an extra layer
The regulation distinguishes roles such as manufacturer, importer and distributor, and links obligations to who places the product on the market. With rental, the mattress in practice often remains in the possession of the same party, which raises the question of who after delivery may or must make changes to the passport if the mattress is for example steam cleaned or fitted with a new cover. That is not a small detail: supervisory authorities look at who at any given time is responsible for the accuracy of the data, not only at who once produced the mattress. In the knowledge base with explanations per situation it shows how these roles relate to each other, also outside the classical purchase-sales relationship.
What changes with each change of tenant
A mattress that is rented usually does not pass directly from one user to the next. There is a moment of cleaning or inspection in between, and sometimes a repair. If that step changes anything about the product, such as different cover material or a replaced core, that should be reflected in the underlying data. Who records that and how often it happens is something you must arrange with your own process; the regulation itself does not prescribe a fixed frequency. What is certain is that the passport remains linked to the physical product via the QR code, regardless of how many rental cycles it goes through.
Where you record this in practice
In most rental models, the responsibility for maintaining the data lies with the same party that also acquired the mattress or placed it on the market. This is usually not the hotel chain or institution that uses the mattress, but the rental organization itself. Good agreements about this belong in the contract with the party hosting your passport, just as you would do with a software supplier. Via an explanation of where the information in the passport comes from you can see which steps are involved, from initial delivery to later adjustment.
Whether rental in your situation truly requires a different approach than sales depends on how your business is organized and which role each party fulfills in the chain. A lawyer or the competent supervisory authority can assess that for your specific situation; this article only describes the general distinction.
Would you like to quickly see which documents are relevant for your situation? With a few questions you get a first indication, and in the frequently asked questions there are answers to comparable questions about rental, lease and shared use.