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MATTRESSES · ESPR PRIORITY PRODUCT GROUP

Digital Product Passports for Mattresses

Mattresses are an ESPR priority product group. The Commission working plan points to 2029 for adoption of a mattresses delegated act—not a compliance deadline. Final product scope, DPP requirements, and application date remain pending.

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Current position

Regulatory status at a glance

The ESPR framework is in place; a future mattresses delegated act will determine product-specific requirements.

Priority

ESPR priority product group

The 2025–2030 ESPR working plan includes mattresses among its product priorities.

Study context

JRC study scope is not law

The JRC priority study considered indoor bed mattresses as a working product group. Its definition does not establish the final legal scope.

Indicative timing

2029 adoption target

The working plan points to 2029 for delegated-act adoption. This is indicative, not a company compliance or application deadline.

Uncertainty

Requirements are not final

Final scope, DPP fields, ecodesign rules, access rights, and application timing remain pending.

Potential scope

Who may be affected

Mattress manufacturers, brands and private-label operators, importers, and component suppliers may need to prepare information for products placed on the EU market. Final applicability depends on the delegated act and each operator’s role.

Economic operators

  • Mattress manufacturers
  • Brands and private-label operators
  • Importers
  • Suppliers of foams, springs, textiles, latex, and other fillings

JRC priority-study working definition only—not adopted legal scope:

  • Indoor bed mattresses considered as a product group in the study

Regulatory sequence

Mattresses DPP timeline

The product-specific act and its application date are still pending; planning dates are not compliance deadlines.

  1. 2024

    ESPR establishes the framework

    Regulation (EU) 2024/1781 establishes the framework for ecodesign requirements and Digital Product Passports.

  2. April 2025

    Mattresses included in priorities

    The ESPR and Energy Labelling Working Plan 2025–2030 includes mattresses.

  3. Current status

    Mattress-specific details pending

    The Commission describes horizontal DPP infrastructure and its registry; final mattress-specific scope and requirements remain pending.

  4. 2029Indicative

    Delegated act planned

    This is the indicative adoption year in the working plan, not a company compliance or application deadline.

  5. Application dateNot yet defined

    Compliance start depends on final delegated act

    No mattresses application date has been defined; it will depend on the adopted product-specific rules.

Confirmed framework

What is already known about the DPP framework?

ESPR establishes horizontal DPP concepts where a delegated act requires a passport. It does not yet settle the mattress-specific details.

  • Unique product identity

    A passport is linked to a persistent unique product identifier; the required level for mattresses remains pending.

  • Physical data carrier

    A physical data carrier provides access to a passport; its mattress-specific placement remains pending.

  • Interoperable data

    DPP data uses open standards and interoperable formats and, where appropriate, is machine-readable, structured, searchable, and transferable.

  • Reliable information

    Passport information must be accurate, complete, and kept up to date.

  • Product-specific rules

    Any binding mattress ecodesign and DPP information requirements will be set in a product-specific delegated act.

Pending delegated act

What is still to be defined for mattresses?

Study context and planning dates do not set final requirements. The delegated act must settle these details.

  • Product scope

    Final covered mattress products, variants, and exclusions.

  • Required DPP data

    The final mandatory dataset and ecodesign requirements are not defined.

  • Passport granularity

    Whether passports will be required at model, batch, or individual-item level.

  • Data-carrier placement

    Whether the carrier must be on the mattress, its packaging, or accompanying documents.

  • Access rights

    Which information will be public or restricted to defined actors.

  • Not yet defined

    Application date

    The compliance start will depend on the adopted act.

  • Responsibilities

    The specific duties of manufacturers, brands, importers, and other operators.

Provisional only

Possible data categories to prepare for

These are provisional preparation categories, not a final or mandatory mattress DPP field list. The delegated act will determine any required dataset:

  1. 01Product and model identification
  2. 02Layer, material, and component composition
  3. 03Cover, filling, spring, and foam information
  4. 04Supplier and substance evidence
  5. 05Durability information
  6. 06Recycled content and recyclability, where required
  7. 07Disassembly and end-of-life information
  8. 08Sustainability and environmental information
  9. 09Compliance evidence

Readiness pathway

Five steps to start now

Prepare the product and evidence foundations without assuming future legal requirements.

  1. Map construction variants

    Inventory models, sizes, and construction variants that may need distinct records.

  2. Build layer and component BOMs

    Record layers and components, not only finished-product descriptions.

  3. Trace supplier evidence

    Locate evidence for foams, textiles, springs, latex, adhesives, and treatments.

  4. Assign evidence ownership

    Identify owners for material, substance, and circularity information and updates.

  5. Normalize identifiers and evidence

    Structure product identifiers and evidence links for possible future DPP publication and lifecycle updates.

Ease your transition with Circlepass

Want help working through this list? We can support your team step by step.

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How Circlepass helps

Build workable product-data foundations

Circlepass helps teams connect mattress models, layer and material records, supplier evidence, ownership, and controlled updates for DPP readiness. This is not a certification or compliance guarantee.

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Mattress DPP questions

Is a mattress DPP mandatory now?

No final mattress-specific DPP obligation is in place at the review date. ESPR provides the framework; a future delegated act must specify requirements and timing.

Is 2029 the compliance deadline?

No. 2029 is the working plan’s indicative year for delegated-act adoption, not a compliance or application deadline. The application date is not yet defined.

Which mattresses will be covered?

Final legal scope is pending. The JRC priority study considered indoor bed mattresses under a working product-group definition, but that study definition is not adopted law.

Are imported or private-label mattresses affected?

Potentially. Covered products placed on the EU market may include imports and private-label products. Specific obligations depend on the adopted act and the operator’s role and circumstances.

What material or layer information might matter?

Possible preparation categories include construction layers, foams, springs, textiles, latex, adhesives, treatments, supplier and substance evidence, durability, and circularity. These are not final mandatory passport fields.

What can manufacturers do now?

Map models, sizes, and variants; build component-level bills of materials; trace supplier evidence; assign owners; and normalize identifiers and evidence links. These are readiness steps, not a claim of compliance.

Official EU sources

Regulatory references last checked on 24 September 2026

  1. 01Ecodesign for Sustainable Products Regulation (EU) 2024/1781
  2. 02ESPR and Energy Labelling Working Plan 2025–2030
  3. 03European Commission: Digital Product Passport overview
  4. 04European Commission: DPP Registry
  5. 05European Commission: Guidance for economic operators
  6. 06JRC: ESPR study on new product priorities
  7. 07EU Ecolabel bed-mattress criteria (existing-policy context, not future DPP requirements)