To determine whether the digital product passport for mattresses applies to your company depends primarily on your role in the supply chain. The regulation places the obligation primarily on whoever places a mattress on the European market: the manufacturer or the importer. Anyone who merely resells, rents or uses mattresses, such as a bed specialist shop or a hotel, will often encounter the passport in practice because it has already been provided by the party that made or imported the product.
A second factor also plays a role: the precise moment when this obligation takes effect is not yet fixed. The delegated act that regulates this for mattresses has not yet been published. The European Commission's work plan for 2025-2030 does mention mattresses as a product group for which such an act is being prepared, with 2028 as a target date for publication. Until that text is available, no one can say with certainty from which date and for which mattresses exactly a passport becomes mandatory.
Who is usually in the picture
The regulation works with a number of roles that determine who has which obligation: the manufacturer, the importer and the distributor are the most well-known. A company that has mattresses produced and sells them under its own brand name is generally considered the party responsible for the passport for those products, even if the physical production takes place elsewhere. The same applies to a company that imports mattresses from outside the EU to sell them here. What these roles precisely entail and where the boundaries lie is set out in the concepts of manufacturer, importer and distributor explained.
Who usually falls outside, and where the nuance lies
An installation company that installs mattresses in a care project, an office organisation that procures a few mattresses for a staff room, or a hotel that orders mattresses from a wholesaler: in most cases, the obligation to draw up the passport lies with the supplier, not the buyer. Yet that is not a free pass to do nothing about it. Whoever procures can be asked questions about origin and composition that are answered via the passport, for example in hotel procurement where sustainability requirements are part of the tender. And a distributor has, even without producing anything itself, its own responsibility to check that a passport is present before a product is resold.
If you operate your own brand or have it made to order
The situation changes as soon as a company places mattresses on the market under its own name, even if production is outsourced. Think of a bed specialist shop with its own house brand, or a hotel chain that has mattresses made to its own specifications. In such cases, it is worth checking early under which role the regulation will likely place your company, precisely because that determines who must have the passport drawn up and who is the point of contact for that. You can get a first impression of this with a few questions that show where your company probably stands.
What is already worthwhile doing now
Even without the final date being known, it is useful to now map out which mattresses your company itself places on the market, which you only resell, and which suppliers you source them from. This inventory takes little time and prevents you from having to start from scratch once the delegated act is in place. How we keep track of where information comes from and when it was last updated is explained on the page about the source of our information.
What still needs to follow
Čim bude zverejnená delegovaná právna úprava pre matrace, tu sa doplní dátum a presný rozsah. Kým sa tak nestane, je rozumné v prípade pochybností o svojej situácii konzultovať si oficiálny text alebo kontaktovať príslušný dozorný orgán alebo právnika, najmä ak vaša spoločnosť vedie vlastnú značku alebo dováža matrace z mimo EÚ.
Chcete si urobiť prvé, nezáväzné posúdenie toho, kde sa vaša spoločnosť v tejto reťazi nachádza? bezplatný rýchly scan poskytuje v niekoľkých otázkach indikaciu a databáza poznatkov spája témy, ktoré pre MKB-spoločnosti v odvetví matracov najviac rezonujú.