What data goes into the product passport for mattresses?

What you concretely must do

What is expected of you

The ESPR (Regulation (EU) 2024/1781) sets out in Article 10 the broad requirements that a digital product passport must meet, and in Articles 5 to 7 how the underlying requirements for a product are established. For mattresses, the precise product list will be completed in a delegated act. What is presented here is therefore the structure as set out in the regulation — not the final, mattress-specific data list.

Recording material composition

A mattress typically consists of multiple layers: foam, filling, ticking, and possibly pocket springs. Manufacturers or importers are expected to ensure that the composition is traceable per material layer, not merely as a general summary. For a company with 10 to 100 employees, this usually means that procurement data from suppliers (foam producer, ticking supplier, filling material) must be collected and archived systematically, rather than this information existing only on the production floor or in production planning. How foam type and density are recorded precisely is a question that is addressed separately on the page about how foam type and density appear in the passport.

Substances requiring attention

Certain added substances, such as flame retardants, are sensitive because they fall under both the ESPR and other chemicals regulations. A company is expected to know which substances are processed into a mattress and be able to substantiate this to the party compiling the passport. This is a different issue from merely "complying with the standard": it concerns traceability. Which substances must precisely be reported and under what conditions is set out on the page about which flame retardants must be reported.

Share of recycled material

Where a mattress contains recycled material, that share must be demonstrable, not merely stated. For smaller producers who source foam or filling material from a third party, this means that the supplier declaration or certificate must be a fixed part of the procurement file. Without substantiation, a claim about recycled material in the passport cannot be maintained. The method by which this share can be demonstrated is described on the page about demonstrating the share of recycled material.

Instructions for disassembly and separation

A product passport is not only intended for the sales phase, but also for when a mattress reaches the end of its life. Manufacturers are expected to provide separation instructions: how the layers are separated from each other, which parts are recyclable, which are not. For a mid-sized company, this often means that this information is now being documented explicitly for the first time, whereas previously it only existed implicitly within the production department. See the page about what must be included in a mattress's separation instructions.

Substantiating service life

In addition to material and composition, the expected service life of the product is also considered. This is not a free marketing claim, but a figure that aligns with the performance requirements in Articles 5 to 7 of the ESPR. A company that already uses service life claims in sales materials would do well to check whether those claims align with what must be substantiated later. How that substantiation can be structured is set out on the page about substantiating expected service life.

Where things go wrong in practice

A first situation that often arises: a manufacturer does know which foam type was used, but no longer knows which supplier delivered that foam at which point in time, because suppliers change and files are not kept per production batch.

A second situation: companies take material data from a supplier without checking or archiving it, so that when a question arises later, there is no underlying document to be found.

A third, common situation is that recycled material is mentioned on the packaging or website, but there is no certificate or supplier declaration to support this.

A fourth situation arises with companies that assemble a mattress from components from different manufacturers (for example, a cover from one, a core from another): it is not always clear who is responsible for providing which data to the passport.

A fifth situation: information that already exists here and there — a product sheet here, a safety data sheet there — is not brought together centrally, which means that when filling in the passport, data turns out to be contradictory or outdated. This also relates to the question how current the data in the passport must be, because a passport that is filled in once and then not maintained no longer matches the product that is actually sold.

What you can record

• An overview per mattress model of all materials used, per layer, with details of supplier and batch or lot number.
• Supplier declarations or certificates regarding the proportion of recycled material, archived per purchase order.
• A documentation of added substances, including flame retardants, including the source of that information (safety data sheet, supplier declaration).
• A separation and disassembly instruction per model, drawn up in cooperation with the production department.
• Substantiation of durability claims, for example based on test results or warranty conditions.
• A fixed point of contact within the company responsible for keeping this data current, so that changes in material or supplier are also reflected in the passport.
• An overview of which party (manufacturer, importer, assembler) provides which data, especially when a mattress is assembled from components from multiple suppliers.