How do I demonstrate the proportion of recycled material in a mattress?
The share is based on a method that has yet to be established
The share of recycled material in a mattress is demonstrated using a calculation or measurement method that is specifically established for mattresses in a delegated act under the ESPR. This method determines how the percentage is calculated, on the basis of which data, and what evidence is required. Article 39 of the ESPR (Regulation (EU) 2024/1781) provides the basis for this: this article stipulates that test, measurement and calculation methods are to be established so that data in the digital product passport are generated in a uniform and verifiable manner. Without such an established method, there is no prescribed way to substantiate a recycled content percentage, and therefore no obligation to do so.
Who this applies to, and what it does not
This question is relevant for manufacturers and importers of mattresses that fall under the future product-specific rules for mattresses. It is not relevant for other product groups: each product category receives its own delegated act, with its own requirements and its own method, and the one for mattresses is separate from, for example, textiles or furniture. It is also not yet established that recycled content will actually become a mandatory data point in the mattress passport. Article 10 of the ESPR sets out the requirements that a digital product passport must meet in general, but which specific information elements — including possibly the share of recycled material — become mandatory for mattresses will only be determined once the product-specific act is in place. Until then, this topic is a possibility, not an obligation.
The date is not yet fixed
There is no fixed date yet for when an obligation regarding recycled content for mattresses will take effect, simply because the underlying delegated act does not yet exist. The ESPR work plan 2025-2030 mentions a delegated act for mattresses, with the expectation that it will be published in 2028. That is a schedule, not a commitment: work plans shift, and only with the publication of the act itself will it be established whether recycled content becomes a mandatory data point and, if so, what method must be used to demonstrate it. Until the act is in place, there is no obligation on this point for mattresses, nor is there a prescribed way to substantiate a percentage.
What this means for your approach now
The first step is to monitor the publication of the delegated act for mattresses, as it will determine whether recycled content becomes a mandatory passport data point and which method applies. After that, should that be the case, the same act will likely also establish which calculation method must be used — for example on the basis of mass balance or on the basis of raw material sourcing — through the system set out in Article 39. In anticipation of this, it is worthwhile to ascertain now what share of recycled material is contained in the raw materials used, per component (foam, fibres, textiles, springs, packaging), and to record that data with suppliers. Whoever has this sourcing and material data in order will not have to reconstruct data retroactively once the method is known. Once the requirement and the method are established, that information can be included in the passport of the relevant mattress via matrapas.eu and linked to the QR code on the product.
Where this is based on: Article 10 and Article 39 ESPR
Article 10 of the ESPR (Regulation (EU) 2024/1781) sets out the general requirements that a digital product passport must meet, including that the information contained in it must be reliable, verifiable and up-to-date. Which specific data — such as a share of recycled material — becomes mandatory for a product category is determined for each product category via a delegated act. Article 39 of the ESPR provides that test, measurement and calculation methods are to be established where necessary for the data that must appear in the passport. These two articles together explain why a concrete answer to "how do I demonstrate this" cannot yet be given: the answer lies in the method that is being developed for each product category, and that method for mattresses has not yet been published.
Those who want to prepare now should start by mapping their own raw material flows and recording recycled material percentages per material with their suppliers, so that this data is ready as soon as the delegated act for mattresses clarifies the exact requirement and method.
Where this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 10 (requirements for the digital product passport)
- Regulation (EU) 2024/1781 (ESPR), Article 39 (test, measurement and calculation methods)
The regulation itself is on EUR-Lex. We provide references per statement; you do not have to take our word for it.
What you concretely must do
What is expected of you
The share of recycled material in a mattress is not just a marketing claim you can casually attach to your product. Once this data becomes part of the digital product passport, there are requirements for how you substantiate and supply it. This works differently than free text on packaging.
The percentage must align with what the passport requires
Article 10 of the ESPR (Regulation (EU) 2024/1781) governs which product information is included in the digital product passport, and the share of recycled material belongs there in principle if it is established for mattresses in the product-specific rules. For a company with 10 to 100 employees, this means it is not sufficient to state somewhere "contains recycled foam". It concerns a concrete percentage, per material stream, which must be traceable back to the composition of the mattress. Which data that precisely is and how it relates to the rest of the passport information is described on the page about what data will be included in the product passport for mattresses.
The measurement method must be established, not your own estimate
Article 39 of the ESPR (Regulation (EU) 2024/1781) concerns the test, measurement and calculation methods that must be used to substantiate values in the passport. For a share of recycled material, this is a critical point: an estimate from the supplier, a verbal commitment, or your own calculation based on "approximately half of the filling" is not the same kind of substantiation as a calculation according to an established method. For companies that do not have their own laboratory or test facility, this often means the substantiation lies with the raw material supplier, and that documentation must be requested and retained. How that measurement method precisely looks and where you find the method for your materials is explained on the page about the method by which the values for the passport are measured.
The percentage must remain current
A share of recycled material is not a fixed physical characteristic of a mattress — it changes if the raw material supplier changes, if the foam recipe is adjusted, or if a new batch of filling has a different composition. For a production company, this means that the percentage in the passport is not a one-time entry task, but something that moves with changes in procurement. When and how often this must happen is addressed on the page about how current the data in the product passport must be.
The percentage must be traceable to the correct layer or component
A mattress typically consists of multiple materials: foam, springs, ticking, filling. A share of recycled material presented as a single overall figure for the entire mattress, without making clear which component this refers to, results in a passport that is difficult to verify. This relates to how foam type and density are recorded, because a recycled share is usually expressed per foam type or per layer. See the page about for this how foam type and density are recorded in the product passport.
Where things go wrong in practice
A number of situations come up repeatedly in practice:
- A percentage from the supplier is adopted without substantiation. A raw material supplier states "30% recycled content" in a quotation or technical data sheet, and this figure is literally adopted in the passport without it being clear which calculation method it is based on.
- The share is averaged across different batches or suppliers. When a manufacturer mixes foam from two suppliers, with different percentages of recycled content, an average is sometimes taken without it being established how that average was calculated or which period it covers.
- The distinction between pre-consumer and post-consumer material is lost. Recycled material from production waste (pre-consumer) and recycled material from discarded products (post-consumer) are sometimes lumped together in some substantiations, while this makes a difference for the traceability and credibility of the figure.
- The percentage is not updated when a supplier changes. A mattress that has been in the assortment for some time retains in the product passport the percentage from the original raw material batch, even when the filling now comes from a different supplier with a different recycled material percentage.
- No distinction is made between recycled material and biobased material. These two concepts are confused in conversations with suppliers and sometimes also internally, while the product passport asks for the share of recycled material and not the share of renewable raw material.
What you can record
To keep the share of recycled material substantiated and traceable, it is practical to record the following:
- Technical documentation from the raw material supplier containing the recycled material percentage per material stream or batch, including the calculation method used.
- An internal overview per mattress model stating for each component (foam layer, spring system, filling) what share of recycled material has been applied, and from which production date or batch that applies.
- Correspondence or certificates on the nature of the recycled material (pre-consumer or post-consumer), so that it is clear what the figure is based on if questions arise.
- A change log that records when a supplier or recipe has been adjusted, so that the product passport can be updated in a timely manner.
- A reference to the measurement method used, so that in case of an inspection it is clear according to which system the percentage was determined.
To set up this type of dossiers, matrapas.eu offers templates that align with the data that the platform compiles in the product passport on your behalf. It is also good to know that a share of recycled material in itself does not have to be a trade secret, but that the underlying supplier documentation can be; this touches on the question of whether business-sensitive data about mattresses should be made public. It is also useful to check who will actually have access to this type of supporting documents, which is explained on the page on which data from the product passport each party may view.
This is not legal advice. This page provides general information about the legislation this platform concerns. We do not know your situation. If you are in doubt about your own case, consult a lawyer or the competent supervisory authority.
Written with AI based on the sources above, checked by a human on 2026-08-22. Is something wrong? Let us know — corrections are given priority.