Yes, you can organise part of the digital product passport yourself. Collecting product data — materials, composition, maintenance instructions, warranty period — is knowledge that most companies already have in procurement, production or quality assurance. Where it becomes more difficult is the technical side: having the QR code created according to the correct standard, keeping the data accessible for ten years, and ensuring that the passport moves along as the regulations or your product information changes.
The regulation itself does not require you to engage an external party. Whoever is designated as a notifier — usually the manufacturer or importer who places the mattress on the European market — is responsible for the content and availability of the passport, regardless of who builds it technically. The question is therefore not whether it is permitted, but whether it is practical in your situation.
What primarily requires business knowledge
The bulk of the work is in gathering data that already exists somewhere in your organisation: the material passport from your supplier, the test reports for the mattress, the warranty conditions, and information about recycling or disposal at the end of life. This is work you can do yourself, and often should do yourself, because no one else knows exactly which supplier supplied which foam or which warranty applies to which batch. A good starting point is to check which documents you already have in house and which are still missing; examined per subject what is relevant for your situation gives you a starting point for that.
What requires more technical expertise
The technical side is a different story. The passport must be unlocked via a QR code or similar data carrier, the underlying data must be machine-readable according to a format that the European Commission still has to establish, and the information must remain accessible throughout the entire period — for mattresses, hosting for ten years is currently assumed — even if your company switches software provider or a system is phased out. This requires infrastructure that continues to work, even at times when no one in your company is actively involved. How that data carrier is built exactly and where the underlying information comes from can be read on the page that explains where the data comes from.
The boundary between doing it yourself and outsourcing
There is no fixed point at which doing it yourself is no longer possible and outsourcing becomes mandatory. The decision is practical: do you have someone in-house who can build the technical side and, more importantly, maintain it for years to come? Does your assortment change frequently, meaning passports need to be updated regularly? And does the time that takes outweigh the costs of a party that does this for multiple customers simultaneously? For a company with one or two mattress models, that's different than for a manufacturer with dozens of variants and annual changes.
Another point to consider is continuity. The passport must remain available, even if the person who set it up no longer works for the company or if a self-built system becomes outdated. With outsourcing, that continuity lies with the service provider; with doing it yourself, that responsibility remains with your own organisation, also in the long term.
What is not yet established
The exact technical requirements for the data carrier and data format follow from a delegated act that the European Commission still has to publish; this is currently expected around 2028 within the ESPR work plan, with obligations for mattresses to follow thereafter. As long as that act is not in place, it is difficult to precisely determine what a self-build solution must technically be able to do. If you start on your own now, it is wise to take into account adjustments as soon as the final requirements are known.
Whether doing it yourself makes sense in your situation depends on the size of your assortment, the knowledge you have in-house and the time you can spend on it. For legal responsibility as a supplier, a conversation with a lawyer or the competent supervisory authority remains the appropriate course of action. If you would first like to get an impression of what is involved in your case, then the questionnaire that gives a first indication in a few minutes provides a starting point, and on the overview of costs for both routes you can compare doing it yourself and outsourcing side by side.
Would you like to orient yourself more broadly before making a choice? Take the free quick-scan or browse through the topics in the knowledge bank to see which steps apply in your situation.