Which flame retardants must I report in the product passport?
No fixed list of flame retardants for mattresses yet
There is currently no established list of flame retardants that must specifically be reported for mattresses in the digital product passport. The ESPR (Regulation (EU) 2024/1781) is a framework regulation: it governs how requirements are established, but does not pre-fill those requirements product group by product group. For mattresses, a separate, product-specific regulation (a delegated act) must still be established before it becomes clear which substances, including possibly certain flame retardants, must be explicitly reported and above which threshold. Until that regulation is in place, no one can with certainty point to a list of substance names that is "mandatory" for the mattress passport.
What is certain, however, is the principle on which such an obligation will be based. The ESPR makes it possible to include in the information requirements for a product group which substances of concern are present in a product, so that users, recyclers and supervisory authorities are aware of them. For mattresses, that subject is directly relevant, because flame retardants can be found in mattress foam, ticking and cover layers. But the translation into a concrete list, threshold values and reporting obligation in the passport still has to be made.
For whom this is relevant and for whom it is not
This subject affects manufacturers and importers of mattresses who will have to compile a digital product passport in the future, and the parties that supply them, such as suppliers of foam, filling and textiles. It is about the question which chemical composition of the product must be visible in the passport, not about the question whether a flame retardant in itself is permitted. Authorisation and use restrictions of specific substances are handled through other instruments; the ESPR only regulates whether and how the presence of such substances is reported in the passport.
This therefore does not apply to the question of whether a certain flame retardant is prohibited, and not to product categories outside mattresses — each product group receives its own delegated act with its own information requirements. Nor does it yet apply as a concrete, enforceable obligation, as long as the product-specific regulation for mattresses has not been published.
The date is not yet fixed
There is no confirmed date on which the requirements on flame retardants for mattresses will take effect, and that date will only be mentioned on this page once the delegated act for mattresses has been published. What is certain is the sequence: first the European Commission must establish the product-specific act for mattresses on the basis of Articles 5 to 7 of the ESPR, only then does a concrete, verifiable obligation arise as to which substances must be reported and at what level of detail. Until that act is in place, there is no specific reporting obligation for flame retardants in the mattress passport under the ESPR.
How to approach this in practice
Anyone already working on a product passport for mattresses is well advised to map out the composition of the mattress in advance, regardless of whether the obligation is already established. In concrete terms, this means: first create an overview of which flame retardants are used in which parts of the mattress (foam, filling, ticking, cover layers), per supplier and per product line. Next, it is useful to check whether suppliers already provide this information in a structured manner, or whether this still needs to be obtained through separate enquiries. After that, this information can be recorded separately, outside the passport itself, so that it is ready as soon as the product-specific regulation for mattresses clarifies what level of detail and what threshold values apply. Finally, it is advisable to check periodically whether the delegated act for mattresses has been published, because only then will it become clear which substances must be specifically named and how.
Where this follows from: Articles 5, 6, 7 and 10 ESPR
Articles 5 to 7 of the ESPR (Regulation (EU) 2024/1781) describe how ecodesign requirements are established: a distinction is made between performance requirements (for example, durability, repairability) and information requirements, including information on the presence of substances of concern in a product. These articles provide the framework, but the specific implementation per product group, such as mattresses, takes place via a separate delegated act that has not yet been adopted. Article 10 of the same regulation then governs what such a passport must look like once the content is determined: which data are accessible, to whom, and how these are unlocked digitally via the data carrier. Together, these articles thus determine the route by which any potential reporting obligation for flame retardants comes into being, without the content of that reporting obligation for mattresses already being determined.
What to do
Already map out the flame retardants per mattress component and supplier, store that data in a structured manner, and keep track of the publication of the product-specific regulation for mattresses. As soon as that regulation is published, the concrete list and the associated deadline will be added to this page.
Where this is based on
- Regulation (EU) 2024/1781 (ESPR), Articles 5 to 7 (requirements regarding ecodesign, performance and information requirements)
- Regulation (EU) 2024/1781 (ESPR), Article 10 (requirements for the digital product passport)
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
Flame retardants are substances applied in or to mattress material to reduce flammability. For the product passport, the question is not only whether a mattress has been treated with flame retardants, but also which substance was used for this purpose and in which layer. Regulation (EU) 2024/1781 (ESPR) provides in Articles 5 to 7 the basis for product requirements, including information on substances that are important for circularity and safety. What this concretely means is specified per product group; for mattresses, this specification is not yet definitively established.
Reporting which flame retardant is used
In practical terms, this means that a manufacturer or importer must be able to state which chemical substance or substance group has been applied as a flame retardant in the mattress. For a company with 10 to 100 employees, this is usually not a new question — the procurement department or R&D already has this information, because suppliers of foam, textiles or nonwovens typically include this in their specifications. The change is that this information must now be available in a structured form and per product model, instead of lying somewhere in a supplier file. This directly affects the question what data will be included in the mattress product passport, because flame retardants belong there as separate material information.
Making a distinction between layers and components
A mattress often consists of multiple layers: core foam, comfort layer, ticking, possibly a separate fire barrier. It is common for a flame retardant not to be present in the entire product, but specifically in one layer or in the cover. For the passport, this distinction matters, because it is related to the way in which the material will later be separated or recycled. This linkage makes it worthwhile to consider the flame retardant information together with how I record foam type and density in the product passport, because both are part of the same material description.
Support with a measurement method or test report
Articles 5 to 7 of the ESPR link information requirements to performance requirements: it is not just about the name of a substance, but about a substantiated determination that that substance is present and to what extent. For a company, this means that a declaration from the foam supplier or a test report from a fire test forms the common basis. Which test method or measurement method is precisely expected is part of the broader question according to which method I must measure the values for the passport, because this does not apply exclusively to flame retardants but to material information in general.
Making available for the data carrier
Article 10 of the ESPR describes the requirements for the digital product passport, including that information must be disclosed via the QR data carrier and kept up to date. For flame retardants, this means that a change of supplier or formulation — for example, a switch to a different flame retarding substance — must be reflected in an updated passport for the relevant product version. This is in line with the question how often I must update the data in the product passport, because a substance change is precisely the type of change for which that question becomes relevant.
Where things go wrong in practice
A common situation is that a manufacturer knows that the foam is "treated with flame retardants" but can no longer determine which specific substance the supplier used for this purpose. This happens especially with older stock models or with foam that was purchased through an intermediary.
Another situation arises when the flame retardant is only in the cover and not in the core, but the internal documentation makes no distinction between "mattress" as a whole and the individual components. When filling in the passport, the information is then recorded too broadly or too generically.
It also happens that a company does know the flame retardant internally, but is uncertain whether this information should be made externally visible, because the exact composition is considered commercially sensitive. That touches on the question whether business-sensitive data about mattresses must be made public, and in practice sometimes leads to postponement of the entire product passport completion instead of a targeted assessment.
Furthermore, problems arise when a supplier of ticking or foam changes the composition without communicating this to the party compiling the product passport. The product passport then continues to list an outdated flame retardant while the delivered product has already been modified.
Finally, we observe confusion arising between flame retardants and other chemical treatments, such as agents against house dust mites. Both types of substances are sometimes mentioned in the same breath in supplier documentation, while for the product passport they have a different background and relevance — that distinction also emerges in the question whether information about house dust mites or allergens must be included in the product passport.
What you can record
- An overview per product model of which layer (core, comfort layer, ticking) has received a flame-retardant treatment, and which substance or substance group was used for it.
- The declarations or certificates from foam and textile suppliers in which the flame retardant is named, preferably linked to a specific batch or lot designation.
- Test reports of flame tests that substantiate the presence and effectiveness of the flame retardant.
- An internal agreement with suppliers that a change of flame retardant or formulation is reported before a new delivery takes place, so that the product passport can be adjusted in time.
- A defined distinction between flame retardants and other chemical treatments (such as anti-allergenic agents), so that these are not accidentally combined in the product passport entry.
- A template or fixed format for material information per product layer, so that flame retardant, foam type and any recycled content are recorded consistently — that aligns with how the proportion of recycled material in a mattress is demonstrated, because both pieces of data often come from the same supplier chain.
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.