How do I substantiate the expected lifespan of a mattress?
A substantiated service life is based on a recognised test method
The expected service life of a mattress is substantiated with a test, measurement or calculation method that is accurate, reliable and reproducible — this is the starting point of Article 39 of the ESPR (Regulation (EU) 2024/1781). A figure on service life therefore does not stand alone: it must be traceable to a method that demonstrably leads to the same result upon repetition, and that aligns with what is generally regarded as the state of the art. For mattresses, it has not yet been determined which method that precisely is; this will happen in a product-specific delegated act that builds on the general requirements of Articles 5 to 7 of the same regulation. Until that act is in place, there is no prescribed calculation method for mattresses specifically — but there is the general framework within which that calculation method must fit.
For mattresses within the ESPR framework, not for separate warranty claims
This topic concerns the substantiation of service life information as it will shortly find a place in the digital product passport of a mattress, within the ESPR framework. It is not about a commercial warranty period that a manufacturer already places on a mattress — that is a different type of commitment, with a different legal basis, and falls outside what is regulated in Articles 5 to 7 and Article 39 of the ESPR. Nor is it about marketing statements such as "lasts twenty years" on packaging or a website; such statements are assessed against rules on unfair commercial practices, not against the ESPR. What does fall within this: the manner in which a manufacturer or importer will have to demonstrate that a specified service life in the product passport is based on something, once mattresses fall under a delegated act.
The method for mattresses does not yet exist, but the framework does
No delegated act for mattresses has yet been published, so no date is set for when a mandatory method for substantiating service life comes into force. What is certain, however, is the general framework from the ESPR itself: Article 39 determines that methods must be accurate, reliable and reproducible, and that harmonised standards or common specifications are aligned with as far as possible once they exist. Articles 5 to 7 determine that performance and information requirements — which may include service life — are specified per product group. For mattresses, this specification must still take place. Until that time, there is no legal obligation under the ESPR to calculate or state a specific service life.
What a manufacturer can already document
Even without an established method, it is worthwhile to start documenting now what a statement about lifespan is based on, rather than waiting until the delegated act is in place. In practice, this comes down to a few steps, in the order a manufacturer or importer would follow them. First: document which materials and construction properties affect wear — the type of core material, the structure of the covering, the processing method. Then: if tests are already being carried out (for example on compression, resilience retention or washability of the cover), document the test method used, the test conditions and the assumptions involved, even if those tests are not yet mandatory. Next: keep these underlying reports and calculations separate from the final product passport, so that they can be presented on request without having to be included as standard in the passport. Finally: when choosing a test method, check whether a harmonised standard already exists for the relevant component — not because it is already mandatory for mattresses, but because aligning with it increases the likelihood that the chosen method will also be valid under a future delegated act. Whoever organises this data now will not have to start from scratch when the act is published.
Where this follows from: articles 5-7 and article 39 of the ESPR
The obligation to substantiate claims with a sound method follows from article 39 of the ESPR (Regulation (EU) 2024/1781), which sets requirements for test, measurement and calculation methods in general: they must be accurate, reliable and reproducible and in line with the generally recognised state of the art. Whether and how lifespan for mattresses specifically becomes a mandatory part of the product passport follows from articles 5 to 7, which establish the framework for ecodesign, performance requirements and information requirements per product category — to be filled in via a product-specific delegated act that does not yet exist for mattresses.
Manufacturers or importers of mattresses now would be well advised to get their own substantiation of lifespan claims in order independently of this regulation — via the existing tests and documentation already used — and keep an eye on this page for when the delegated act for mattresses is published and the specific method becomes known.
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 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
Substantiate a durability claim with a method, not with an impression
The ESPR links information requirements for a product to what is laid down in the delegated act for that product group, based on Articles 5 to 7 of Regulation (EU) 2024/1781. For mattresses, it has not yet been determined whether "expected durability" will appear as a mandatory data point in the passport, and if so, in what form — a number of years, a number of use cycles, or a qualitative indication. What can be expected: if a durability is mentioned, it must be traceable to a method. A figure that is based only on experience or on what the industry has always said does not meet the way the ESPR handles product information. For a company of this size, this means that the durability claim is not formulated from marketing or sales, but from a test or calculation procedure that is documented and repeatable.
Measure according to the method established for the product
Article 39 of the ESPR provides that test, measurement and calculation methods shall be established in order to obtain comparable and verifiable results. Once a method is designated for mattresses — for example based on a standard for durability under mechanical load — that is the method that counts, not an internal test setup developed by the company itself. For a medium-sized company, this often means that some of the test work is outsourced to a testing institute, or that test results from the foam or spring supplier are adopted. In either case, the question remains: it must be precisely traceable according to which standard and under what conditions the test was conducted. That aligns with the question according to which method must I measure the values for the passport, which describes the same logic for other data in the passport.
Keep the substantiation traceable to the materials used
The expected durability of a mattress is linked to the materials it contains: the type of foam, the density, the springs, the cover. A durability claim that stands apart from that material choice is difficult to defend once someone asks about it. In practical terms, this means that the substantiation of durability is linked to the documentation of the material composition, as described under how do I record foam type and density in the product passport. If a supplier changes the foam density, the substantiation of the durability may also change — that is a point at which the claim is reviewed again, not automatically carried over.
Keep the claim current as the model changes
An expected durability established at some point for a mattress model applies to that model as it was composed at that time. If the supplier, the filling or the construction changes, the previously established durability is not automatically still valid. How often and at what point data in the passport are updated depends on what is stated in the knowledge base under how often must I update the data in the product passport; for durability, a model change is a logical point to review the substantiation.
Where things go wrong in practice
A common mistake is adopting a durability figure from a comparable model or from a competitor without that figure having been tested or calculated on your own product. That works until someone asks where the figure comes from.
Another situation: the foam supplier provides a test report, but that report is based on a different standard or different load conditions than what is needed for the passport. The report is then used "because there is something there anyway", without checking whether the method aligns.
Also problematic: a durability indication is placed in the past on the packaging or website as marketing text — "lasts twenty years" — and that text then takes on a life of its own, separate from what has been tested or substantiated internally.
Furthermore, it occurs that a durability claim is established upon the introduction of a mattress, but is never reviewed again if the composition of the product later changes due to a new foam supplier or adjusted bed density.
Finally: a company does conduct internal testing, but does not retain the test report in a structured manner, so that when a customer or supervisory authority makes an enquiry, it is not quickly possible to determine which test belonged to which mattress version.
What you can record
- The test report or calculation on which the durability claim is based, including a statement of the standard or method used.
- A link between the test report and the specific mattress version (material composition, density, supplier) to which the report relates.
- The date on which the durability was established and the moment when it was last reviewed.
- Correspondence or certificates from suppliers providing components of the substantiation, such as foam or spring data.
- An internal moment or process to review the durability claim in the event of changes to material or construction — a fixed review point may be linked to maintenance information, as also discussed under do I need to indicate how to maintain or have a mattress repaired, because maintenance and durability are substantively connected.
- A template in which, for each mattress model, the source, method and date pertaining to the durability claim are recorded, so that this does not remain scattered in emails or test reports.
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.