Mattresses are in the first ESPR wave — and most of the industry has not noticed.

When the European Commission published the first ESPR working plan in April 2025, it named a short list of priority final products: textiles, tyres — and furniture, with mattresses explicitly called out. That makes mattresses a genuine first-wave Digital Product Passport group, ahead of hundreds of product categories that will only follow in later working plans. Yet most mattress and bedding manufacturers, and the importers who bring their products into the EU, still assume DPP is a problem for batteries and electronics. It is now, indicatively, a problem for them.

In one line: mattresses are explicitly named in the first ESPR working plan (April 2025), so a mattress delegated act — and with it a mandatory Digital Product Passport roughly 18 months later — is a question of when, not if; the manufacturers who assemble their material data now will clear it without drama.

Why mattresses, of all things?

Mattresses are one of the clearest circularity failures in the EU economy. They are bulky, awkward to transport, and built from tightly bonded layers — polyurethane foam, latex, steel springs, textile covers, adhesives — that are difficult to separate at end of life. The result is that discarded mattresses overwhelmingly end up landfilled or incinerated, even though the steel, foam and fibre inside them are recoverable in principle. That combination — high waste volume, low recycling rates, and real recovery potential if recyclers only knew what was inside each unit — is exactly the profile the ESPR was designed to fix. A Digital Product Passport gives dismantlers and recyclers the composition data they currently have to guess at, which is why furniture including mattresses made the first working plan while many higher-profile categories did not.

The timeline — what is fixed and what is indicative

Here is where the mattress obligation actually stands:

In force now: the ESPR framework — Regulation (EU) 2024/1781, in force since July 2024. It creates the DPP mechanism but sets no product-specific requirements itself.
Decided: the first working plan (April 2025) names furniture including mattresses as a priority final-product group, alongside textiles and tyres.
Still to come: a delegated act for the group, which will define the exact data requirements and dates. The first delegated act of all is expected around 2026 for iron and steel, with textiles indicatively following in 2027; the furniture and mattress act has no scheduled date yet.
The rule of thumb: once a delegated act enters into force, obligations typically bite roughly 18 months later.

So no mattress maker needs a passport this year — but the window between "the act is adopted" and "your products cannot ship without one" is short, and the preparatory work is front-loaded.

What a mattress DPP will likely carry

The definitive data list will be written in the delegated act, but the ESPR framework and its horizontal priorities — recyclability, repairability, durability — make the direction predictable. Expect a mattress passport to cover:

Material composition — foam types and grades, latex, spring steel, textile fibres, fire-retardant treatments and adhesives, layer by layer.
Substances of concern — chemicals that affect safe recycling and reuse.
Durability and expected lifetime — the performance data behind longevity claims.
Disassembly and recyclability — how the unit comes apart and which fractions are recoverable.

Most of this data already exists in your organisation — in spec sheets, supplier declarations and test certificates. It is just scattered across suppliers and formats, which is the real compliance problem to solve.

What to do now

The sensible move before the delegated act lands is data-readiness, not panic: inventory your range, identify which material and supplier documents you hold and which you need to request, and get the data into a structured, verifiable form. That way the ~18-month window becomes an administrative exercise instead of a supply-chain scramble. This is what PassPer is built for: our AI extracts the passport data from the documents you and your suppliers already have — spec sheets, certificates, declarations — with human review, then publishes it as an eIDAS-sealed passport behind a GS1 Digital Link QR, filed with the EU registry when your group's act requires it. Plans from €79/month with a free 30-day pilot, or start with the free readiness check to see where your data gaps are.

Frequently asked questions

Is there already a DPP law specifically for mattresses?

Not yet a dated one. The ESPR framework is in force (July 2024) and the first working plan (April 2025) names furniture including mattresses as a priority product group — but the concrete obligations arrive via a product-specific delegated act that has not yet been adopted. Once it enters into force, companies typically get around 18 months before the requirements bite.

We import mattresses into the EU rather than manufacture them. Does this affect us?

Yes. ESPR obligations attach to the economic operator placing the product on the EU market — for goods manufactured outside the EU, that is the importer. You will need a compliant passport for the mattresses you place on the market, and you cannot outsource the legal accountability to your factory.

What data will a mattress DPP require?

The exact list will be set in the delegated act, but based on the ESPR framework and its horizontal priorities, expect material composition (foams, latex, springs, textile covers, adhesives), substances of concern, durability, and disassembly and recyclability information — the data recyclers need to recover steel, foam and fibre instead of sending the whole unit to landfill.

When should we start preparing?

Before the delegated act is adopted. The hard part of a DPP is not publishing it — it is assembling verified material and supplier data across your range, which for a multi-supplier mattress portfolio takes months. Companies that build data-readiness now can comply within the ~18-month window without a fire drill; a free readiness check is a sensible first step.

See where you stand — three ways, all free.

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