Getting Safety Right in Foam Materials: GPSR Standards Are Now Part of Our Industry

Erkin Kocaman 

Chemical Engineer / Chemical Assessment Specialist (CAS)

Doruksistem

Foam materials form not only the foundation of comfort and innovation in the mattress industry, but also the basis of product safety, traceability, and competitive sustainability. With the entry into force of the European Union’s General Product Safety Regulation (GPSR, 2023/988/EU) on December 13, 2024, every mattress and its components placed on the market must now have a holistic and scientifically proven safety profile.

Each component used in mattress production—core foam, support and comfort layers, surface materials, textiles, adhesives, and all other elements—must undergo separate testing, analysis, and risk assessment for the overall safety of the final product. It is no longer sufficient to simply claim “the final product is safe”; the safety of each structure, chemical, and function must be proven individually and documented with technical files and up-to-date test reports.

In this article, the safety of foam products and, in general, mattress components under GPSR, steps of risk assessment, substantiating claims through testing, process management, and the role of safety in innovative competition are discussed. At the end of the article, we also address the latest developments regarding digital market surveillance in Turkey and the GÜBİS system.

1. Holistic Safety of Mattress Components: Each Part, a Separate Responsibility
Modern mattresses consist of many different components such as polyurethane foam layers of varying density and function, springs, textiles, coverings, adhesives, flame retardants, barrier layers, and auxiliary protectors. According to the GPSR, the effect of each component on human health and on the overall product must be analyzed separately and substantiated by the manufacturer with a technical file.

• The mechanical integrity of core and support foams, risk of excessive deformation, permanent collapse, or small parts
• Allergenic, irritant, or toxic substance emissions from surface coatings and textiles
• Volatile organic compound (VOC) and potentially hazardous chemical contents of adhesives and additives
• Possible effects of flame retardants and other chemicals on human and environmental health

For all these elements, separate conformity tests, chemical analyses, risk assessments, and, when necessary, special scenarios (for example, child/elderly users, misuse, long-term exposure) must be prepared. The production batch, test reports, chemical content, and risk analysis of each component must be kept up to date in the manufacturer’s archive and be ready to be presented to authorities upon request.

2. Chemical Safety, Transparency, and Innovation
Chemical content management is of critical importance in the safety of foam and mattress components. GPSR makes it mandatory for every chemical substance present in the product to comply with the EU’s REACH regulation and global safety criteria. In particular, manufacturers and importers must:

• Ensure the safety of all used isocyanates (for polyurethane foam), plasticizers, flame retardants, and additives with respect to human health and the environment,
• Address VOC emissions, biocompatibility, heavy metal content, and similar factors,
• Confirm whether any chemicals listed as Substances of Very High Concern (SVHC) under REACH are present in their products,
• Provide complete traceability of all ingredients and ensure retrospective reporting can be done rapidly when necessary.

Developing alternative raw materials and environmentally friendly formulations is indispensable not only for sustainability but also for market access and competitiveness.

3. Risk Assessment: A Scientific, Up-to-Date, and Detailed Approach
Risk assessment is no longer a one-page procedure; it is a scientific process in which each component, function, and claim is analyzed separately and kept up to date. Under GPSR:

• Possible risks should be analyzed at every stage of the product life cycle (production, storage, logistics, consumer use, and disposal),
• Use scenarios should be considered from a broad perspective, including reasonably foreseeable “misuse” (such as children jumping on the bed, incorrect placement, or different responses in different age groups),
• Chemical, physical, biological, and mechanical risks (deformation, breakage, toxic emission, microbial growth, etc.) should be detailed,
• Risk analysis should be updated and documented in the technical file for each new component or production change.

Topics that may be overlooked in the risk analysis process include:

• Promotional claims on packaging or advertising not fully matching the product,
• Component changes (foam from a different supplier, alternative adhesives, etc.) creating new risks,
• Missing market-specific regulatory requirements (e.g., for children’s products, sensitive groups),
• Risks that may arise during long-term exposure, disposal, or recycling phases.

 4. Testing, Claims, and Demonstration of Performance
GPSR makes it compulsory to substantiate all features claimed for products and their components on the market with objective, up-to-date, and standard-compliant tests. Features such as “flame retardant” are tested with EN 597-1/2, EN 1021, FMVSS 302; claims such as “anti-bacterial,” “anti-mite,” or “hypoallergenic” with microbiological tests like ISO 22196, ASTM E2149; physical performance and durability with mechanical tests such as EN 1957, EN 1607, EN 16890; and chemical safety with VOC, phthalate, and heavy metal analyses.

All these tests must be carried out with a comprehensive and continuous verification system, taking into account different variants of the product and components as well as varying usage conditions. Up-to-date test reports and conformity documents should be prepared for each product model, and for every claim highlighted on product packaging and promotion, scientific and independent evidence must be provided by the manufacturer. This approach strengthens the validity of safety claims and brand value.

5. Evolving Responsibilities of Economic Operators
With GPSR, the definition of “economic operator” is no longer limited to the manufacturer; importers, distributors, authorized representatives, responsible persons, and online platforms have also become critical links in the safety chain. Each actor now has much greater responsibilities in the safe marketing of the product, traceability, recall, keeping technical documentation up to date, and transparent communication with the consumer.

• Manufacturer: Primarily responsible for all design, production, conformity, risk analysis, and technical documentation processes. Each component (foam, textile, spring, adhesive, chemical additive, accessory, etc.) must be proven compliant with separate technical files and up-to-date test reports.
• Importer: Responsible for ensuring the accuracy of technical files and conformity provided by the manufacturer for all products from outside the EU, and for presenting these to authorities when required.
• Distributor: Responsible for ensuring the continuity of safety during storage, shipment, and sales, and for taking swift action when nonconformity is detected.
• Authorized Representative and Responsible Person: Especially in non-EU production, responsible for complete archiving of technical files and conformity documents, and managing official notifications.
• Online Platforms: Required to present complete product safety information in online sales channels, to publish warning/recall notices, and to play an active role in complaint processes.

All these actors must be able to instantly share current risk and conformity files upon authority request; they must respond rapidly, digitally, and transparently to consumer complaints and official requests. In this sense, GPSR strengthens product safety processes both horizontally and vertically within the supply chain, which is also the key to competitive advantage.

6. Process Management and the Importance of Expert Support
To implement a comprehensive and multi-layered regulation such as GPSR effectively, processes must be continuously updated, technical documentation must be kept dynamic, and always ready for inspection. Static procedures are no longer sufficient. Proper interpretation of risk matrices, ensuring traceability at the component level in both production and distribution, and periodic conformity checks by independent and impartial organizations have become obligatory.

Mattress products are not limited to foam alone. Surface textiles, covering fabrics, innerspring systems, barriers, adhesives, flame retardants, and all other components are included separately within the scope of GPSR. Thus, not only the main material but all the elements making up the mattress are expected to meet separate conformity and safety criteria. For manufacturers and importers, this makes it mandatory to ensure the traceability of every batch, every component, and every supply chain link through digital conformity management systems.

Expert consultancy and regulation tracking are now not only legal requirements but also indispensable parts of innovation and sustainable competition. Accurate technical knowledge, rapid regulatory updates, and effective crisis management are highlighted as the keys to long-term brand value and international market access.

7. Digitalization, Market Surveillance, and GÜBİS in Turkey
Digitalization has ushered in a new era in market surveillance and product safety management. In the European Union, the Safety Gate system centrally collects notifications from both authorities and consumers; risky products are rapidly made public, and recall decisions are disseminated throughout the Union.

In Turkey, risky and recalled products are announced instantly through GÜBİS (https://guvensizurun.ticaret.gov.tr), and the obligations for transparent notification and reporting for manufacturers and importers have been strengthened. With the entry into force of the “Regulation on Market Surveillance and Inspection of Products Placed on the Market Through Remote Communication Tools” in April 2025, all products offered on online sales platforms are now subject to the same safety, traceability, and rapid recall requirements as those in traditional sales channels.

Conclusion: Proven Safety in Every Component, Demonstrable Competitiveness
As much in technical polyurethane foam products as in textiles, springs, chemicals, and all other mattress components, proving the safety of each part individually, managing risks, and supporting claims with scientific tests are the keys not only to compliance but also to lasting brand value and global competitiveness. Especially in the mattress industry, the significance of these developments is even greater: GPSR covers not only polyurethane foam, but all mattress components—including surface textile, covering, innerspring, barrier, adhesive, accessories, and every kind of chemical content—individually. The specific safety profile of each part must be scientifically proven by tests, archived in technical files, and presented to the competent authorities when necessary. Thanks to digital infrastructure, these processes become faster, more transparent, and more accessible, creating significant advantages in terms of trust, brand value, and competitive sustainability in the sector.

In an environment where e-commerce is rapidly expanding and product safety risks are increasing in online sales channels, product safety control and management in Turkey are also rapidly spreading and strengthening with the general product safety approach. In the near future, it will be critically important for all sector players—especially manufacturers and importers—to continuously monitor developments in both legislation and digital surveillance tools.

In the future, consumer trust and international market access will only be sustainable with a transparent, innovative, and holistic approach to product safety. For all these processes to be managed completely and sustainably, it is essential that manufacturers, importers, and other economic operators work with independent technical consultancy, regulatory expertise, and proactive compliance monitoring—not only to meet legal obligations, but also as the key to sectoral competition and brand reliability.

References
- European Union. (2023). Regulation (EU) 2023/988 of the European Parliament and of the Council of 10 May 2023 on general product safety and repealing Directive 2001/95/EC. Official Journal of the European Union. https://eur-lex.europa.eu/eli/reg/2023/988/oj
- European Chemicals Agency. (n.d.). REACH Regulation (EC) No 1907/2006. Retrieved from https://echa.europa.eu/regulations/reach
- International Organization for Standardization. (n.d.). EN/ISO test standards.
- European Commission. (n.d.). Safety Gate: Rapid Alert System for dangerous non-food products. https://ec.europa.eu/safety-gate
- Republic of Turkey, Ministry of Trade. (n.d.). GÜBİS – Güvensiz Ürün Bilgi Sistemi. https://guvensizurun.ticaret.gov.tr
- Republic of Turkey, Ministry of Trade. (2025). Regulation on Market Surveillance and Inspection of Products Offered on the Market via Remote Communication Tools. Retrieved from https://ticaret.gov.tr