According to which method must I measure the values for the passport?

What you concretely must do

What is expected of you

The measurement method follows from the delegated act, not from your own choice

Article 39 of the ESPR (Regulation (EU) 2024/1781) stipulates that products falling under a product group must be tested, measured and calculated according to reliable, accurate and reproducible methods. For mattresses, this is a product group-specific delegated act that still needs to be established; that act will then contain the requirements from Articles 5 to 7 of the ESPR (ecodesign, performance and information) and the associated measurement method. In practical terms, this means for a mattress manufacturer or importer that there is currently no fixed test standard to point to: which value must be measured using which method is only established once the act for mattresses is published. A company with 10 to 100 employees can thus prepare for the type of data that is likely to be requested, but cannot yet establish a definitive test procedure as being "the" legal method.

Harmonised standards take precedence once they exist

If the Commission has had a harmonised standard drawn up for a specific requirement and its reference has been published, compliance with that standard constitutes proof that the measurement requirements have been met. For a company, this means it is advisable to monitor which standards are designated for mattresses, once they are available, rather than developing a test method yourself. An internal quality department that is already collecting test reports from suppliers would be well advised to note according to which standard each report has been drawn up — this will make the transition easier later.

Absence of a standard does not exempt from the obligation to measure

As long as there is no harmonised standard, the delegated act itself may prescribe a method, or temporarily refer to other recognised specifications. This means that a manufacturer cannot wait until everything is fixed before anything is measured: the obligation to demonstrably work with reliable data remains relevant even during the transition period, especially for values that are already being requested on other grounds, such as the proportion of recycled material in a mattress or the data on foam type and density.

The method must be reproducible between suppliers

Article 39 asks not only for a method, but for a method that, upon repetition and by different parties, leads to comparable results. For a mattress manufacturer who sources components — foam, springs, fabric — from multiple suppliers, this means that the test results of those suppliers must be mutually comparable. A company with multiple production lines or brands would be well advised to inventory now whether suppliers use the same test method, so that when the final method is published, data do not arise that are mutually incomparable.

Where things go wrong in practice

A standard is applied retroactively to old test data. A manufacturer has test results from five years ago and assumes they can be used without further ado for the passport. If the final method differs from the test setup used at the time, that result is no longer usable without reassessment.

Suppliers each test according to their own (foreign) standard. With a mattress composed of foam from supplier A, springs from supplier B and fabric from supplier C, upon closer inspection it turns out that each supplier uses a different test standard for, for example, flame-retardant properties. This makes it impossible to compile a single coherent passport without first clarifying which standard was applied where.

Internal test results are confused with legally required measurement methods. A quality department tests, for example, the lifespan or durability of a mattress using an internally developed method. That is valuable for product development, but is not automatically the same method that will later be used for substantiating the expected lifespan will be requested in the passport.

Measurement is postponed until the delegated act is in place. Some companies defer all measurements "until it is certain", so that when the act is published, no test data is available and everything must be set up from scratch — while competitors who built on existing standards have a head start.

Confusion between the measurement method for the passport and that for another label. A manufacturer already using a textile label assumes the measurement method for that also applies to the product passport. This is not automatically the case; see also the question of whether a separate textile label remains necessary alongside the digital product passport.

What you can record

• An overview per raw material or component (foam, springs, ticking, filling) of which test standard the supplier currently applies, including test date and testing institute.
• Test reports from suppliers, stating the method used and the version or publication date of that method.
• An internal log recording which values are already being measured (for example for demonstrating the share of recycled material) and according to which method, so that later comparison with the final standard is possible.
• Correspondence with suppliers asking about the test method behind supplied certificates, particularly for data that are sensitive, such as the disclosure of flame retardants used.
• A designated contact person or process to monitor standard updates, so that changes in harmonised standards are noticed in time.
• A template for internal quality control with space for "method applied" and "method required under regulation", so that the difference between the two remains visible until the final method is established.