How do I record foam type and density in the product passport?
Foam type and density are part of the material data
Foam type and density will soon become part of the material data that appears in the digital product passport of a mattress. This is information that describes the composition of the product — for example, whether it is polyurethane foam, cold foam, viscoelastic foam or latex, and at what density (typically expressed in kg/m³) that foam is produced. This type of data fits with what Article 10 of the ESPR (Regulation (EU) 2024/1781) describes as the basis for the requirements of a product passport: information on the material composition, performance and durability of a product. For mattresses specifically, it has not yet been determined which exact data field will be mandatory and in which format — this follows from the delegated act that will be drawn up for this product group.
Who this applies to, and what it does not
This information is relevant for mattress manufacturers and importers who will soon have to compile the passport, and for parties working downstream with that data, such as bed specialists and hotel procurement who are looking for substantiated material information. This is about the recording of physical material characteristics of the product itself — not about sales information, pricing or merchandising. It is also not about a certification or approval mark for the foam; the ESPR articles cited here are about the structure of the passport and the methods by which data is substantiated, not about quality standards for foam itself. Which exact density thresholds apply, or whether it applies to all types of mattresses or only certain categories, is not yet established in the sources provided and is therefore not specified here.
No fixed date yet, but an established framework
There is no published delegated act that specifically establishes for mattresses which data on foam type and density is mandatory, and therefore no firm implementation date either. What is established is the general framework from the ESPR itself: Article 10 describes what the requirements for a product passport can be based on, and Article 39 describes that test, measurement and calculation methods will be developed to substantiate data in the passport. Once the delegated act for mattresses is published, it will specify which material data is mandatory, how it must be measured and from which date. Until then, there is no legal obligation for mattresses specifically to include foam type and density in a digital product passport.
What a manufacturer can do now
The practical sequence starts with your own records: what data on foam type and density is already available per product line, and in what form (supplier specification, test report, internal production data)? That is work that is useful anyway, regardless of the exact end date of the regulation. Next, it is worthwhile to follow when the delegated act for mattresses is published, because only then will it become clear which data field is mandatory and according to which test method density must be measured — this follows from Article 39. After that, it is a matter of matching the existing data to the final format of the passport, and ensuring that the data is traceable to the physical product to which the QR code will point. Those who already keep this data in a structured manner will only need to adapt the format once the act is published, rather than having to gather the data from scratch.
Where this comes from: Article 10 and Article 39 of the ESPR
Article 10 of the ESPR (Regulation (EU) 2024/1781) describes the general basis on which requirements for a digital product passport are established, including information about material composition and product sustainability. Article 39 of the same regulation describes that test, measurement and calculation methods are established to make data in the passport reliable and comparable. Both articles are general provisions from the ESPR itself; the specific implementation for mattresses — which data field for foam type and density is precisely mandatory, and according to which standardised method density must be measured — follows from the delegated act that is being drawn up for this product group and which has not yet been published.
If you are already producing or importing mattresses, it is best to start by putting your existing technical documentation on foam type and density per product line in order. Once the delegated act for mattresses is published, the exact implementation will appear here.
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
Name foam type unambiguously
A mattress with cold foam, polyether foam, latex or a combination thereof must be recognisable in the digital product passport as what it actually is. Article 10 of the ESPR (Regulation (EU) 2024/1781) determines that the digital product passport contains the product information established for the relevant product group, and foam type is a characteristic in mattresses that directly affects composition, recyclability and service life. For a company with 10 to 100 employees, this means in practice that the designation which may currently only be internal or on a supplier datasheet must be recorded consistently and at product level — not as a marketing term ("comfort foam") but as a technically identifiable foam type. Which exact classification and terminology will become mandatory is determined by the delegated act for mattresses; until then, it is advisable to align now with the classification also described in what data will be included in the mattress product passport is described in.
Support density with a measurement method
Density (usually in kg/m³) is not a matter of writing down a figure, but of a figure that has been established in a traceable manner. Article 39 of the ESPR determines that values included in the passport must be based on the test, measurement and calculation methods designated for the product group. For the day-to-day practice of a manufacturer or importer, this means that the density of a foam block must not simply be taken from a supplier datasheet without knowing according to which method it was determined. A company that purchases foam from different suppliers is well advised to document per foam type which measurement method underlies the stated density; more information on that methodology is in according to which method must I measure the values for the passport.
Monitor coherence with other material data
Foam type and density are not separate from other mandatory data. A foam with a certain density may be linked to the proportion of recycled material, to the presence of flame retardants, or to the way in which the layer can be separated at end of life. For companies that produce multiple mattress models with variants in foam composition, this means that foam type and density must not be kept as a separate data point but as part of the total material file per model. Anyone processing recycled material in the foam is well advised to document those two data points in relation to each other; see for this how do I demonstrate the proportion of recycled material in a mattress.
Traceability to the production line
Because mattresses are often produced in different density variants of the same foam type (for example a firmer and a softer version), the recording in the passport must be traceable to the specific product variant or SKU. For a medium-sized manufacturing company, this means that the link between internal product codes and the passport data must be complete, so that a foam change in production does not accidentally lead to an outdated or incorrect passport for an already running series.
Where things go wrong in practice
Taking over supplier data without method. A manufacturer receives a density value from the foam supplier on a datasheet, without mention of the measurement method, and pastes that value directly into the passport. Upon inspection or a question from a customer, there is then no way to demonstrate how the value was determined.
Marketing name instead of foam type. In trade, commercial names are often used ("viscoelastic comfort plus") instead of the underlying foam type. This is confusing for the party compiling the passport and can lead to an incorrect or incomplete designation.
Density averaged only across a mattress with multiple layers. For mattresses with multiple foam layers of different densities, a single average value is sometimes provided, whereas the individual layers are relevant for recyclability and separation at end of life.
Foam recipe modification not implemented in the passport. A producer modifies the composition or density of the foam for production technical or cost reasons, but the existing passport of the model is not adjusted. This directly relates to the question of how often data must be updated, see how often must I update the data in the product passport.
No distinction between test report and production data. A density value from a one-time test report of a prototype is used for the entire production series, without having established whether series production yields the same value.
What you can record
- An internal material overview per mattress model with foam type, density and the corresponding SKU or product code.
- Documentation of the measurement method used to determine density, including reference to the test report or testing body.
- An overview of density values per layer for mattresses with a layered foam structure, instead of a single average value.
- Correspondence or specifications from the foam supplier in which foam type and density are unambiguously described, separate from commercial designations.
- A change log in which foam recipe or density modifications per model are recorded, so that it is clear which passport belongs to which production period.
- A link between the foam data and other material records, such as data on recycled material or fire retardants, so that the passport as a whole remains consistent.
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.