What must the disassembly instructions for a mattress contain?

What you concretely must do

What is expected of you

Designate materials that must be able to be disassembled

The ESPR drives on products that can be disassembled into usable material streams at the end of their life. For a mattress, this means in practice: the cover, the foam layers, any pocket springs, the edge reinforcement and the base must be recognisable and separable. Articles 5 to 7 of the ESPR (Regulation (EU) 2024/1781) assign the delegated act to lay down per product group what exactly is required in terms of disassembly and material separation — for mattresses that act does not yet exist, but the structure of the regulation makes clear that an instruction describing how to distinguish the main materials will be part of the core of the task. For a company with 10 to 100 employees, this is mainly a matter of documenting what the own production line already knows: which layers are in it, in what order are they stacked on top of each other, and with what tool or what procedure do they come loose.

Adjust the instruction to who will use it

A separation instruction is not marketing text and not a technical drawing for the own factory — it is intended for a recycler, a municipal waste processor or a dismantling company that has never seen the mattress being made. That requires a different tone: step by step, with the material type mentioned as soon as a layer is removed. Whoever specifies foam type and density in the product passport, already has that information available and can reuse it directly in the separation instruction, so the recycler does not have to guess whether a layer is cold foam or polyether.

Have the instruction align with the digital product passport

Article 10 of the ESPR (Regulation (EU) 2024/1781) describes what must be in the digital product passport and how it must be accessible via the data carrier on the product. A separation instruction that only lies on paper in a drawer does not align with that approach — the intention is that relevant information stays with the product, even after it has changed hands or ends up with a processor years later. For a mattress manufacturer, this means that the separation instruction becomes a permanent part of the same data set that also goes to the passport, not a separate document that was once created for the quality department and is not updated afterwards.

Recognisability of materials on the product itself

A separation instruction only works if the person following it can find the materials in the mattress. This raises the question what data will be included in the product passport for mattresses: if material composition, layer structure and any fastenings are already recorded there, the separation instruction can refer directly to it instead of describing the same information again and possibly slightly differently.

Where things go wrong in practice

A first recurring problem is that the separation instruction is written by someone who already knows the mattress from inside and outside, causing steps to be skipped that seem obvious to an outsider but are not — "remove the cover" without indicating whether staples, glue or zips are involved.

A second situation is an instruction that was created for one mattress model but is reused without modification for the entire collection, while the layer structure differs per model. When checked or when a customer asks, that difference only becomes apparent then.

A third point is that the instruction is separate from the rest of the product information: the foam type mentioned in the instruction does not match what is documented elsewhere about the share of recycled material or with the material data in the passport itself. Such contradictions usually arise because different departments work with different versions.

A fourth situation concerns flame retardants: if a mattress has been treated with them, this is relevant for someone who later dismantles or processes the product, but this information is often kept separately for regulatory purposes and not linked to the disassembly instruction. Whoever must report which flame retardants have been applied, would do well to ensure that the same data also appear at the point where the mattress is taken apart.

A fifth pitfall is that the instruction is written and then never updated again, even when the foam supplier changes or a new layer is added. That touches on the broader question how current the data in the product passport must be — a disassembly instruction that does not change with modifications to the product eventually loses its value for the processor who relies on it.

What you can record

• An overview per mattress model of the material layers in the order they appear, with an indication of the material type per layer.
• A description of how each layer is detached: by hand, with tools, by cutting open a zip or removing staples or adhesive bonds.
• An indication of any flame retardant treatments per layer, linked to the data already being kept about them.
• A link between the disassembly instruction and the material data that are also included in the digital product passport, so that both sources remain consistent.
• Version control that indicates when the instruction was drawn up and at which product modification it was last reviewed.
• A designated person within the company responsible for keeping the instruction up to date, so that changes in production are automatically implemented.

For companies that prefer not to set up these components from scratch, matrapas.eu offers templates that align with the data structure of the digital product passport, so that the disassembly instruction is not merely a separate document alongside the passport but becomes part of it.