The Flexible PU guidance covers mechanical recycling of flexible PU and depolymerisation where the output is re-polyol. RP applies to waste recycling, RC to relevant subsequent stages, and SP may be relevant to input preparation. This is not a separate scheme or an automatic requirement to hold all three certificates.
Flexible polyurethane foams are used in mattresses, upholstered furniture and comfort products. Their recycling requires attention to dismantling, the presence of other materials, binders, moisture and subsequent processing. “Guidance for Interpretation – Flexible Polyurethane”, Version 1, explains how these issues are assessed within RecyClass.
The guidance primarily concerns Recycling Process (RP) and, where applicable, Recycled Plastics Traceability (RC). Its decision trees also refer to Sorting Process (SP) when assessing input preparation. These schemes perform different roles within a single material chain.
1. What does the Flexible PU guidance cover?
The document supplements the RecyClass Audit Schemes, Auditor Guidance, Audit Checklists and procedures. It does not replace them or establish a separate certification scheme or another Module A–D.
It covers two routes:
- Mechanical recycling of flexible PU — including shredding, grinding, rebonding foam particles with a binder, steam activation, drying and subsequent cutting, peeling or lamination.
- Chemical depolymerisation of flexible PU — where the assessed output is the recycled polyol fraction, or re-polyol.
The guidance does not cover rigid PU or thermochemical processes such as pyrolysis. In the chemical route, it does not extend the assessment to any reaction product, such as recovered isocyanates. Where a process or configuration falls outside the decision trees, the certification body must contact RecyClass before continuing the assessment.
2. How do the roles of SP, RP and RC differ?
Sorting Process — input preparation and control
For whole used mattresses or mixed bulky waste, the organisation must demonstrate how PU foam is separated from latex, textiles, covers, metals and other fractions. Removed materials must be identified and weighed so that the quantity of PU entering recycling is supported by reliable evidence.
The decision trees require checking whether an upstream operation or the applicant’s activity can be assessed under Sorting Process or “Guidance for Interpretation: Input Waste”. This does not automatically require every PU recycling facility to obtain a separate SP certificate. The actual allocation of operations and the approach to input control must be established. Insufficient control of material preparation prevents certification from proceeding.
Recycling Process — transforming waste into recycled material
Where an organisation receives material legally classified as waste and performs a recycling operation, RP is the relevant route. For Flexible PU, the output may be appropriately defined rebonded foam or re-polyol covered by the depolymerisation route.
Recycled Plastics Traceability — subsequent use of the material
Where an organisation receives material with product status or an output from an earlier recycling operation, the applicability of RC depends on its role, process and claims. The earlier recycling operation must be covered by RP or another route accepted by RecyClass.
Product status alone does not prove recycled origin. PU trims, by-products and other residues cannot automatically be treated as waste, recycled material or a basis for a recycled-content claim. Evidence of origin, previous handling and the recycling operation is required.
3. Mechanical recycling: what exactly does the certificate cover?
The assessed output may be a rebonded foam block, cylinder, sheet, roll, mat core, component or finished product. The selected stage must be clearly defined, measurable and connected to input and production records.
The scope ends at the last stage where physical traceability and measurement are maintained. If a facility can demonstrate a cylinder’s mass and composition but loses record continuity during peeling, lamination or assembly, it should not extend the certification result to the finished product. In that case, the scope stops at the cylinder.
Production data must account for PU as well as binders, pigments, additives, adhesives, recirculated material and significant losses.
4. Moisture: adjusting the balance does not change recycled-content rules
Steam activation, drying and storage can affect foam mass. The guidance allows a documented moisture correction in Volume Reconciliation. The correction is for the material balance and must not alter the standard recycled-content calculation.
Two methods are provided:
- Method A — representative gravimetric moisture testing. Samples, including the foam surface and core, are dried to constant mass. Where several samples are used, the moisture fraction is calculated from their total wet and dry masses.
- Method B — batch mass difference. Dry inputs before steam activation are compared with the output at the assessed stage, provided that all significant additions and losses other than water are known or conservatively estimated.
For Method A, the moisture fraction is (wet mass − dry mass) / wet mass. The corrected output mass for reconciliation is measured output mass × (1 − moisture fraction).
Calculation example: with representatively verified moisture of 5% and a measured output mass of 1,000 kg, the corrected mass for reconciliation is 950 kg. This does not justify automatically increasing the declared recycled-content percentage.
A correction must not conceal unknown losses or missing records. The actual flows must first be reconstructed; only then can the remaining difference be justified as moisture.
5. Trims and recirculation: how can double counting be avoided?
Recirculated material does not automatically become 100% recycled content. It retains the documented recycled fraction of the original production batch or period.
If 10 kg of trims comes from foam containing 50% recycled content, it carries 5 kg of documented recycled material into the next production. The full 10 kg cannot be counted as that fraction.
The facility should know the recirculated mass, its source batch or period, recipe, original recycled-content value and destination. Continuous recirculation requires a model that carries these data between periods and prevents the same mass from being counted repeatedly.
In the guidance example, a batch with 90% recycled content produces trims with the same percentage. A subsequent batch made from 90 kg of those trims and 10 kg of virgin material contains 81% recycled content. Repeating the operation yields 72.9%, rather than another 90%.
Where the original batch or period, recipe or recycled-content value cannot be demonstrated, the recirculated mass is assigned 0% recycled content.
6. Depolymerisation: the final re-polyol is the assessed output
Routes such as glycolysis, acidolysis, hydrolysis or aminolysis require a description of the reaction and actual flows. The process diagram should include PU input, reagents, tanks, reaction stages, filtration, separation, additions, storage, dispatch, losses and side streams.
A theoretical description or stoichiometric calculation may explain the technology, but does not replace production records, physical traceability and controlled blending.
The certified output may be re-polyol after filtration and quality release or the final blend after quality adjustment and the addition of other ingredients. If virgin polyol, stabilisers or other substances are added before dispatch, the assessment must be based on the actual composition released for sale.
Adding virgin material does not in itself rule out certification. It must, however, be included in the standard recycled-content calculation and the physical controlled-blending model.
7. Tanks, batches and material carried over between campaigns
The unit to which recycled content is assigned may be a released reactor batch, an isolated tank batch, a storage campaign, an IBC filling batch or a bulk dispatch. It must connect a specific quantity of material with production, storage and dispatch records.
Where several batches are mixed in a tank, the composition model should include opening stock, inflows, additions, transfers, partial withdrawals and closing stock. Where the composition can be reconstructed, the calculated weighted value is assigned to the corresponding dispatches.
If the exact weighted composition cannot be reconstructed but all contributing batches and their recycled-content values are known, the lowest verified value is used for the relevant campaign or period. Where even this conservative assignment cannot be supported, traceability is insufficient.
Material remaining in a tank between campaigns must be carried into the next opening stock together with its mass, composition and recycled content. It cannot be omitted merely because a new accounting period has started.
8. What role does CertiPUR play?
In mechanical recycling, a valid CertiPUR certificate with an appropriate scope may support compliance with RP Requirement 9.9, Product Legislation. Its scope must match the assessed foam, product family and input configuration.
CertiPUR does not replace RecyClass assessment of recycled origin, traceability, the material balance or recycled-content calculation.
CertiPUR does not certify liquid re-polyol. A chemical recycler producing this output must provide documentation appropriate to the chemical product’s status and intended use. Any later assessment of foam manufactured from that polyol is a separate stage.
9. What data are needed for a Flexible PU assessment?
Before defining the scope, organise:
- a description of operations and a material-flow diagram;
- the input’s legal status, source and processing history;
- records of dismantling, sorting and the masses of removed fractions;
- measurements of PU, binders, additives, recirculated material, output and losses;
- the definition and specification of the certified output;
- evidence supporting any moisture correction;
- recipes and the traceability model for recirculation;
- for re-polyol: certification units, tank composition and links to dispatches;
- product-legislation documentation and appropriate supplier evidence.
The records should reproduce the actual process. A summary of purchases and sales alone does not resolve unknown composition, missing masses or uncontrolled input preparation.
FAQ
Does Flexible PU mean all flexible packaging?
No. This guidance concerns flexible polyurethane, primarily foams. It should not be confused with general guidance for PE or PP films.
Does every company need SP, RP and RC?
No. The relevant scheme depends on the operation, the material’s legal status and the claims. SP may be relevant to input preparation, RP to waste recycling and RC to appropriate subsequent stages of material use.
Can RP cover a finished product made from rebonded foam?
The guidance allows this scope where the assessed stage remains measurable and traceable and the applicable requirements are met. The product name alone does not determine eligibility.
Can moisture be used as a missing entry in the material balance?
Not without evidence. Only demonstrated moisture can be corrected, after actual inputs, additions and losses have been accounted for. This does not change the rules for calculating recycled content.
Does recovered polyol always contain 100% recycled content?
This cannot be assumed automatically. The value must follow the appropriate calculation for the final composition and documented flows, including any addition of virgin ingredients.
Find the appropriate certification scheme
Start by defining the input material, the operation and the output for which a claim will be made. Details of the individual routes are available on the Sorting Process, Recycling Process and Recycled Plastics Traceability pages.
When contacting Almaland, provide the material status, foam source, a description of dismantling or recycling and the output form. This will help establish the appropriate route and certification scope. Go to the contact form.
