what should I do if the label with the QR code comes loose or wears out

If the label comes off, the passport usually still exists

A QR code on a mattress is not the product passport itself, but only the means of access to it. The passport is a dataset that is hosted separately and remains available for ten years; the label on the mattress is merely the data carrier by which someone can access it with a scan. If that label comes off, discolours or becomes unreadable through wear, the underlying data does not disappear — only the physical access on that particular unit is lost. That is a practical problem (a customer, shop assistant or hotel buyer can no longer scan the data), but not a legal problem in the sense that the passport is "lost".

Who this applies to, and where the boundary lies

This topic concerns the physical data carrier on the product: the label, hang tag or stitched attachment with the QR code affixed to the mattress itself. It does not concern the question of how that code gets there in the first place — that is a separate choice that varies per production line and sales channel, and which is covered more extensively in how the QR code for the product passport gets onto the mattress. It also does not concern the question of whether the same QR can already be affixed to existing stock before sale; that is a different scenario, covered in applying a QR code to already manufactured mattresses. And it does not concern the passport as a dataset — the question of how long that data remains in existence is separate from the question of whether the label goes along with it, and is explained separately in how long the product passport remains available.

There is no fixed date yet, but a clear point of departure

Exactly when the obligation to maintain a digital product passport with data carrier will apply to mattresses is not yet established: this will follow from a delegated act that has yet to be published. Until that time, nothing changes in existing mattress sales as a result of this regulation. What is already established, regardless of the precise date, is the principle set out in Article 11 of the ESPR (Regulation (EU) 2024/1781): the data carrier on the product must be durable, legible and able to withstand use for the period of use appropriate to the product type. For a mattress — a product that is in use for many years, withstands washed covers and is sometimes moved — this is a real point of attention when choosing the label, and not something that only becomes apparent afterwards.

What to do if the label on a mattress is unreadable

The first step is to check whether the mattress can still be identified by another route than the QR code itself, such as a printed serial number, a product code on a separate label, or records with the manufacturer or seller. The passport itself is linked to the unique identification code of the product, not to the label — see also how each product receives a unique identification code. Once that code is known, the passport can in most cases still be looked up, for example via the register in which passports are registered (see the European register of digital product passports).

The second step, for a manufacturer, importer or seller who encounters this problem on multiple products, is to assess whether a replacement label with the same link can be re-applied. Because the data carrier is linked to the identification code and not to a physical piece of paper, a new label with the same QR content is in practice often possible to make and apply, as long as the underlying link between product and passport has been maintained.

The third step is for the longer term: when choosing the label in advance, take into account the environment in which the mattress will end up. A mattress that is used intensively and washed in a hotel places different demands on a label than a mattress that remains at home under a cover. Material choice, method of attachment and position of the label are therefore practical choices that reduce the risk of loss or unreadability beforehand, rather than having to repair it afterwards.

For those who manage the passport themselves via their own inventory or ERP system, it is also worthwhile to check whether the link between product code and passport is properly documented there, so that a replacement label does not have to be built from scratch — more on this at linking the product passport to an ERP or inventory system.

The substantiation: articles 11, 16, 17 and 13 of the ESPR

Article 11 of the ESPR (Regulation (EU) 2024/1781) sets the technical requirements for the data carrier, including durability and readability during the relevant period of use of the product. Article 16 governs the requirements for labels in connection with the digital product passport, and article 17 prohibits the use of counterfeit or misleading labels — relevant as soon as a replacement label is made, because that label must maintain a faithful link with the registered passport. Article 10 describes the substantive requirements that the passport as a dataset must meet, regardless of the physical carrier. Article 13 governs the register in which passports and their identification codes can be found, which forms the basis for tracing a product even without a readable label.

What to do now

Those who already produce or sell mattresses with a QR label are well advised to record the identification code of each product separately from the label, so that a damaged or loose label does not become a dead end. For those who still have to choose which label and which attachment it will be, it is wise to test that choice against the expected service life and use of the mattress, rather than discovering afterwards that the label does not survive the first wash.