CertiPUR-US® Shredded Foam Policy

The CertiPUR-US^® certification program (“Program”), administered by the Alliance for Flexible Polyurethane Foam, Inc. (“AFPF”), certifies that flexible polyurethane foams used in bedding, upholstered furniture, and similar end-use products meet rigorous, independently verified standards for material content (including absence of certain harmful chemicals), emissions (low VOCs), and overall performance.

The process of shredding CertiPUR-US^® certified foam—whether conducted by a Participating Foam Producer using its own certified foam, or by a registered manufacturer or retailer sourcing foam or pre-shredded foam from third-party foam producers or suppliers—creates an elevated risk of unintentional or unauthorized mixing with uncertified foam during handling, storage, processing, or assembly. For purposes of this Policy, “Applicant” means any entity seeking approval from AFPF to use the CertiPUR-US^® mark or name in connection with products containing shredded foam. Such contamination could allow uncertified material to enter the supply chain and bear the CertiPUR-US^® mark, thereby undermining consumer trust and Program integrity. For purpose of this policy, all references to “foam” refer to flexible polyurethane foam.

To safeguard the certification’s credibility while enabling legitimate use of shredded CertiPUR-US^® certified foam in finished products, any Applicant seeking to use the CertiPUR-US^® mark or name in connection with a product containing shredded foam must:

Fully complete and submit the CertiPUR-US^® Shredded Foam Application Form (the “Application Form”) online (a pdf form can be provided to the Applicant via email if the online form cannot be completed by the Applicant).
Obtain explicit written approval from the AFPF prior to applying the CertiPUR-US^® certification mark (name, logo, or seal) to any product containing shredded foam.

Definitions

Capitalized terms not defined herein shall have the meanings ascribed to them in the current CertiPUR-US^® Certification Standards Manual, Technical Guidelines for Slabstock Foam or Molded Foam (as applicable), and other official Program documents.

For purposes of this Policy and the Application Form, a “Participating Foam Producer” means the Applicant pours or produces flexible polyurethane foam, is already approved as a participating foam producer in the CertiPUR-US^® Program and seeks approval to use the CertiPUR-US^® mark or name on its own finished products containing shredded foam. Participating Foam Producers will not pay an additional fee annually to be part of the CertiPUR-US^® Shredded Foam program.

A “Registered Manufacturer” means an Applicant that is registered with CertiPUR-US^® to use the CertiPUR-US^® name, logo, or related terms, does not itself produce the foam at issue, and purchases pre-shredded foam or foam it shreds in-house from one or more Participating Foam Producer(s) or Participating Foam Supplier(s) for use in finished products. Registered Manufacturers will be invoiced after review of their applications and each Registered Manufacturer must pay a recurring annual fee of $1,000 to obtain and maintain approval under the CertiPUR-US^® Shredded Foam program. This fee is due each year, for so long as the Registered Manufacturer uses the CertiPUR-US^® mark or name in connection with products containing shredded foam.

A “Registered Retailer” means the Applicant is registered with CertiPUR-US^® to use the CertiPUR-US^® name, logo, or related terms; and re-sells products made with shredded foam that are produced by a Registered Manufacturer or Participating Foam Producer (who has registered with the CertiPUR-US^® shredded foam program) and labeled under the retailer’s own name, brand or private label. Registered retailers will not pay an additional fee to be part of the CertiPUR-US^® Shredded Foam program.

A “Participating Foam Supplier” means a foam producer or supplier that is registered with, or approved under, the CertiPUR-US^® Program and from whom a Registered Manufacturer purchases foam or pre-shredded foam covered by a valid, unexpired CertiPUR-US^® certification for use in finished products.

Applicability by Applicant Type

Because the CertiPUR-US^® Program includes three categories of Applicant with materially different operations, the requirements of this Policy apply to each Applicant only to the extent relevant to its activities, as set out below. Where a requirement refers to producing, shredding, handling, testing, or otherwise processing foam, it applies only to Applicants that perform those activities.

Participating Foam Producers and Registered Manufacturers

Applicants that produce, shred, or otherwise handle foam are subject to all requirements of this Policy, including the affirmation of standard Program requirements (Section 1), the sourcing and chain of custody requirements (Section 2), the chain of custody and recordkeeping requirements (Section 3), and the process controls and monitoring requirements (Section 4).

Registered Retailers

A Registered Retailer does not produce, shred, or handle foam and instead re-sells finished products made with shredded foam by a Registered Manufacturer or Participating Foam Producer approved under this Policy. Accordingly, the requirements of Sections 1, 2, 3, and 4, and any other requirement expressly tied to the production, shredding, handling, or testing of foam, do not apply to a Registered Retailer. A Registered Retailer must instead: (i) source all products bearing or intended to bear the CertiPUR-US^® mark or name solely from a Registered Manufacturer or Participating Foam Producer that is approved under this Policy for shredded foam; (ii) maintain records identifying each such supplier and the products sourced, retain those records for at least five (5) years from the date of sale, and provide them to the AFPF or its authorized auditors within ten (10) business days of a written request; and (iii) comply with all remaining requirements applicable to it, including the labeling and mark-usage requirements, incident reporting (Section 5), third-party verification and enforcement (Section 6), indemnification (Section 7), and the miscellaneous provisions (Section 8).

1. Affirmation of Standard Program Requirements

This Section applies only to Participating Foam Producers and Registered Manufacturers. It does not apply to Registered Retailers, which do not produce, shred, or handle foam.

The Applicant expressly acknowledges and agrees that except with respect to the physical property testing requirements found in Sections 7a and 7b of the CertiPUR-US^® Technical Guidelines for Slabstock and Molded Foam, all other CertiPUR-US^® Program requirements apply.

These requirements include, but are not limited to:

Comprehensive testing protocols for content and emissions.
Strict verification of the absence of prohibited substances (e.g., certain flame retardants, heavy metals, phthalates, formaldehyde, ozone depleters, and others listed in the Technical Guidelines).
Emissions limits ensuring low volatile organic compound (VOC) levels for acceptable indoor air quality.
Precise labeling, mark-usage, and promotional guidelines to prevent misleading claims.
Ongoing record-keeping and documentation obligations.
Rights of the AFPF (or its designated representatives) to conduct audits, inspections, and random verification testing.

The Applicant must at all times adhere to the most current versions of all Program documents.

2. Sourcing and Chain of Custody Requirements

This Section applies only to Participating Foam Producers and Registered Manufacturers. It does not apply to Registered Retailers, which do not produce, shred, or handle foam.

The Applicant must affirm that:

100% of the flexible polyurethane foam subjected to shredding and ultimately incorporated into the finished product originates from foam that is covered by a valid, unexpired CertiPUR-US^® certification for the exact foam family or families involved at the time the foam is produced or purchased, as applicable.
All sourced foam consists solely of virgin (newly produced) material acquired specifically for certified applications and must not derive from: (i) uncertified scrap foam from manufacturing processes; (ii) post-consumer recycled material; or (iii) any other source that is not subject to CertiPUR-US^® certification and the associated quality controls.

3. Chain of Custody and Recordkeeping Requirements

The documentation requirements of this Section apply to Participating Foam Producers and Registered Manufacturers. They do not apply to Registered Retailers, whose recordkeeping obligations are governed by the Applicability by Applicant Type provision above.

To substantiate these commitments, the Applicant shall maintain comprehensive, auditable chain-of-custody documentation for a minimum of five (5) years from the date each product is manufactured. This documentation must include, at minimum:

For Registered Manufacturers, purchase orders and corresponding invoices from each Participating Foam Producer or Participating Foam Supplier.
For Registered Manufacturers, supplier declarations or certifications confirming CertiPUR-US^® status, applicable foam family or families, and virgin origin.
Internal receiving and inventory records tracing material from receipt through shredding and final incorporation.

All such records must be provided to the AFPF or its authorized auditors within ten (10) business days of receiving a written request. The records must clearly demonstrate an unbroken chain of custody from the original Participating Foam Producer to the finished product.

4. Process Controls and Monitoring

This Section applies only to Participating Foam Producers and Registered Manufacturers. It does not apply to Registered Retailers, which do not produce, shred, or handle foam.

The Applicant must establish, document, and continuously maintain process controls reasonably designed to prevent uncertified or contaminated foam from entering shredded material destined to bear the CertiPUR-US^® mark. Such controls shall be appropriate to the scale and nature of the Applicant’s operations and consistent with industry best practices for quality control and material segregation. Key controls include:

Physical segregation through dedicated production lines, isolated storage zones, clearly labeled containers, and distinct handling procedures that prevent any commingling of certified and non-certified foam at every stage.
Ongoing monitoring via batch and lot tracking systems, unique identification labeling, routine quality control inspections, and periodic internal audits to verify adherence.

All monitoring records, including logs of quality checks and audit findings, shall be retained for at least five (5) years from the date of manufacture. All such records must be provided to the AFPF or its authorized auditors within ten (10) business days of receiving a written request.

5. Incident Reporting

In the event of any actual contamination, suspected contamination, material non-conformance with the requirements, material deviation from established controls, or other issue that could reasonably be expected to affect the integrity of products bearing the CertiPUR-US^® mark, the Applicant shall: (i) provide written notification to the AFPF within twenty-four (24) hours of discovery (or the next business day if discovery occurs on a weekend or holiday), including a description of the incident and initial containment steps taken; and (ii) within five (5) business days of the incident, submit a corrective action plan outlining root-cause analysis, remedial measures, preventive actions, and timelines for implementation. The level of detail required in such notifications and plans shall be proportionate to the severity and scope of the incident.

6. Third-Party Verification and Enforcement

The foam in finished products containing shredded foam may be subject to independent third-party laboratory verification by laboratories accredited under the CertiPUR-US^® Program. Cost of this sample shipment and testing will be paid by the CertiPUR-US^® Program. Verification testing confirms ongoing compliance with all applicable standards, including chemical content restrictions, emissions thresholds, and absence of prohibited substances. The Applicant agrees to cooperate fully and without delay in all verification activities, which may include:

Providing representative samples of the shredded foam used in finished products as requested by AFPF or its authorized auditors.
Participating in a virtual audit by video conference.
Granting reasonable access to facilities, production areas, storage locations, and relevant records during normal business hours and upon reasonable advance notice, except in cases of suspected fraud or imminent safety concerns where immediate access may be required. The Applicant may require AFPF representatives and auditors to execute reasonable confidentiality agreements and comply with the Applicant’s safety and security protocols.
Supplying requested documentation within the timeframes established by the AFPF or its auditors.

Any failure to achieve certification standards in verification testing, refusal or unreasonable delay in cooperation, material misrepresentation in the Application Form or supporting documents, failure to pay applicable Program fees, or other material non-compliance may result in the following actions:

Immediate suspension or permanent revocation of the right to use the CertiPUR-US^® mark and name.
Mandatory removal of the mark and name from all affected products (including recall or relabeling obligations where applicable).
Additional enforcement actions deemed appropriate by the AFPF, up to and including potential legal action.

7. Indemnification

The Applicant agrees to indemnify, defend, and hold harmless the AFPF, its officers, directors, employees, agents, representatives, and affiliates from and against any and all claims, demands, damages, losses, liabilities, costs, and expenses, including reasonable attorneys’ fees and court costs, arising directly or indirectly from: (i) any breach or non-compliance with the CertiPUR-US^® Program requirements or the terms of this Policy or the Application Form; (ii) any misrepresentation, inaccuracy, or omission in information provided under this Policy or the Application Form; and (iii) any unauthorized, improper, or misleading use of the CertiPUR-US^® certification mark.

8. Miscellaneous Provisions

Nothing in this Policy is intended to replace, supersede, or modify any existing certification agreement, producer approval, registration, supplier verification, or other obligation between the Applicant and the AFPF. In the event of any inconsistency or conflict, the more stringent requirement shall control, and the current CertiPUR-US^® standards and Technical Guidelines shall prevail in all cases. The AFPF may, in its reasonable discretion and in a manner proportionate to the severity of the issue, suspend or revoke approval to use the CertiPUR-US^® mark and name, mandate corrective actions, require additional testing, or take other measures. Where feasible, the AFPF will provide the Applicant with prior written notice and a reasonable opportunity to respond; however, in cases of imminent risk of contamination or serious threat to Program integrity, the AFPF may take immediate action without advance notice, followed by prompt written notification and an opportunity for the Applicant to address the matter.

This Policy is to be read in conjunction with the CertiPUR-US^® Shredded Foam Application Form. Approval under this Policy is granted only after the AFPF’s review and approval of a properly completed Application Form.