The 2026 chemical-compliance cliff is here. Do you know where your mattress stands?
ClearSupply is a screening service for mattress and bedding brands: we take your bill of materials and Safety Data Sheets, map every chemical against the wall of 2025–2027 US state PFAS and flame-retardant laws and against the independent Bedroom Chemistry Atlas, and hand you back a defensible readiness report — from a firefighter-led research publication that takes no money to change a grade.
Request a manual pilot audit →The cliff, on a calendar
A brand that sells into all 50 states is very likely non-compliant somewhere already. The laws almost never say "mattress" — they say "textile articles," "textile furnishings," or "upholstered furniture," and your ticking, cover, and bedding fall inside those definitions. Resolving that scope, per state, is the work.
CA · MN · CO · WA — PFAS in textiles
California (AB 1817), Minnesota (Amara's Law), Colorado (SB24-081) and Washington already restrict PFAS in textile articles and furnishings. AB 1817 tightens from 100 ppm total organic fluorine to 50 ppm on Jan 1 2027.
New York — FRs banned in mattresses
The Family and Fire Fighter Protection Act bans new mattresses & upholstered furniture with intentionally added halogenated / organophosphorus / organonitrogen flame retardants.
Maine — the big one
Maine's PFAS-in-products law reaches textile articles, upholstered furniture and juvenile products. The most consequential near-term ban; a Currently-Unavoidable-Use notification is the only way to keep selling a covered category past its date.
EPA — TCEP "unreasonable risk"
EPA's final TSCA risk evaluation for the flame retardant TCEP names "foam seating and bedding products" by name. A §6 restriction is the next step.
California Prop 65 — PFAS
100+ citizen-enforcer 60-day notices have already hit crib mattress pads, mattress pads and pillows for PFOA/PFOS. This is active legal risk today, not a future date.
SOR/2025-270
Canada's updated Prohibition of Certain Toxic Substances Regulations add Dechlorane Plus and DBDPE to the existing PFOS/PFOA/HBCD/PBDE prohibitions. A PFAS-in-textiles phase is proposed federally.
The fact every brand should lead with — and most don't know. No US or Canadian law requires flame-retardant chemicals in a mattress. The federal standards (16 CFR 1632 & 1633) and California's TB117-2013 are performance standards — met with an inherent fire-barrier fabric, not added organohalogen chemistry. California's own bureau states TB117-2013 "does not regulate the use of flame retardant chemicals." The chemical was never the safety. The barrier is. Knowing that is the difference between a defensible product and a recall.
The five artifacts you receive
A pilot engagement is a package of five distinct artifacts — not a single PDF, but the same set of documents that enterprise compliance programs deliver to procurement teams and retailers. Each artifact is designed for a different audience inside your company.
1. Compliance Readiness Report
The core bound document. Structured like a formal gap assessment, with a cover, revision-history table, and front matter before the first data row. The revision history exists even for v1.0 — because your report will need to be re-run as laws change, and the baseline date matters.
- Executive summary — Overall RAG status (Red / Amber / Green) per jurisdiction, your Disclosure Grade (A / B / C), and the three risks that need action now.
- Scope — Which products and SKUs were assessed, which materials reviewed, which jurisdictions are in scope, and which regulations were evaluated versus deferred.
- Methodology — How each finding was sourced, which evidence tier applies (peer-reviewed / regulatory / industry / inferred), and what those tags mean — so a lawyer or retailer auditor can reproduce the logic.
- Per-requirement findings register — The central table: one row per regulation, with columns for the requirement, your current status, the evidence (tier-tagged), the identified gap, risk level (Critical / High / Medium / Low), recommended action, suggested owner, and target date.
- Remediation roadmap — Gaps re-sorted by risk, with sourcing or testing actions on a 30 / 60 / 90-day horizon.
- Appendices — Cited sources (with evidence tiers), any test data you supplied, and regulation excerpts with effective dates.
2. Sleep-Category Restricted Substances List (RSL)
A branded RSL scoped to the sleep environment — the shared language your sourcing team can hand to every foam, adhesive, fire-barrier, and cover supplier. Every row carries the minimum schema that makes an RSL auditable: not just the name and limit, but the test method and sample preparation, so a lab knows exactly how to generate a conforming report.
| Substance (family) | CAS | Limit | Materials in scope | Test method / sample prep | Regulatory driver |
|---|---|---|---|---|---|
| PFOA (long-chain PFAS) | 335-67-1 | 100 ppm TOF → 50 ppm Jan 2027 | Cover fabric; ticking; fill; fire barrier | ASTM F2905 / EPA 537.1; combustion IC; 1 g textile | CA AB 1817; ME LD 1503; MN SF1345 |
| TCEP (OPFR) | 115-96-8 | No intentional use (NY); TSCA §6 pending | Foam core; adhesives; fire barrier | EPA 8270D; LC-MS/MS; 1 g / 20 mL DCM | NY FR ban; EPA TSCA final risk eval. Sept 2024 |
| ⋯ continued for every regulated substance across your material set | |||||
The RSL is seeded from the chemical families in the Bedroom Chemistry Atlas and cross-referenced against the AFIRM RSL, ZDHC MRSL, and OEKO-TEX STANDARD 100 substance lists. Where limits conflict across jurisdictions, the most restrictive is applied and all sources noted. It also includes a testing matrix — a colour-coded grid mapping each substance to each material type (foam / adhesive / fire barrier / cover / fill), so your suppliers know which tests apply to them and which don't.
3. Supplier Certificate-of-Conformity template + Declaration form
A one-page document your purchasing team can issue to every foam, adhesive, fire-barrier, and cover supplier, asking them to confirm in writing that their product meets the RSL limits above. Includes a substance declaration the supplier signs. This builds the audit trail that a retailer's compliance team — or a regulator — will eventually request. Most small brands don't have these. The ones that do are significantly easier to defend.
4. Regulatory Watch Memo
A short dated memo covering what is changing in the specific states and countries you sell into: REACH SVHC additions, Prop 65 new listings, PFAS restriction updates, flammability-rule changes. Each item is tagged by evidence tier (enacted / proposed / anticipated) and time horizon. Delivered with the initial report as Issue 1 of an ongoing cadence. The watch memo converts the engagement from a one-time PDF into a living program — because the law doesn't stand still, and a gap assessment that isn't kept current is stale within twelve months.
5. Certifications-Coverage Translation
One page that maps exactly what your existing seals test — and what they leave uncovered — so you can talk to a retailer, journalist, or lawyer without inadvertently overstating the protection you've verified.
| Seal | What it actually tests | What it does NOT cover |
|---|---|---|
| GREENGUARD Gold | VOC emissions from the finished product in a test chamber — 360+ compounds; total VOC ≤ 220 µg/m³; annual retest required. | Chemical content (what's in the foam, adhesives, or cover). PFAS content. FR chemistry identity. Cover fabric if not separately submitted. |
| CertiPUR-US | Foam only: bans PBDE FRs, heavy metals above limits, formaldehyde, CFCs; phthalates; VOC emissions ≤ 0.5 ppm total. | Cover fabric, ticking, adhesives, fire barrier, fill. Does not require FR-free foam — only bans specific FR classes. PFAS not tested. |
| OEKO-TEX STD 100 | Textile content: 100+ substance classes — azo dyes, phthalates, heavy metals, biocides, PCP. Product Class II applies to direct-skin articles (bed linen, mattress covers). | Foam core (unless separately certified). Emissions. FR chemistry unless in scope. The certificate names which components were tested — not always the whole product. |
| MADE SAFE | Full-formulation ingredient screening against hazard lists — aims to exclude all chemicals of concern across the whole product. | Analytical lab testing (screening is hazard-list-based, not lab-confirmed). Upstream chemistry visibility depends on supplier-reported data. |
How a pilot runs
- You send us your bill of materials, the SDS for your foam and adhesives, your cover's topical-treatment details, and any certifications you hold.
- We map each disclosed chemical to its Atlas hazard band and to the specific laws it triggers — reading Sections 3, 10, and 11 of every SDS together, because the composition line rarely tells the whole story.
- You receive all five artifacts inside 2–3 weeks. Every date-sensitive item is flagged for re-verification, because dates in this regulatory landscape move.
Why an independent — and why us
Every certification mark and testing lab in this category is paid by the brand it evaluates. GREENGUARD, OEKO-TEX, MADE SAFE, CertiPUR-US, SGS, Intertek — all sell the brand a seal or a service. None of them will publish the sentence "your GREENGUARD Gold covers emissions, but you disclose nothing about your adhesives," because that sentence bites a paying customer. ClearSupply can — because we take no money to move a grade, and our whole reason to exist is the independence.
The person reading your SDS is a 19-year career firefighter who has built a live, independent publication of 145+ evidence-tier-tagged compound pages, a Sleep Environment Score, and the Brand Emission Registry. The combustion authority is real, and it is exactly the authority that lets us say the flame-retardant chemistry your customers fear was never what made the mattress safe.
Patient zero was our own supply chain. Before we screened anyone else, we ran the full method on a mattress we import ourselves — pulling the supplier's bill of materials and Safety Data Sheets, mapping every disclosed chemical to the Atlas, and generating the compliance report. We built the tool on our own product first. Now we're opening it to five external pilots.
The firewall. ClearSupply is Embr's services arm. It is walled off from the independent research: paying for a pilot audit, or later to host your verified lab data, never buys a better grade in the Atlas or the Brand Emission Registry, and never influences the Sleep Environment Score. The methodology that produces every grade is public and identical for everyone. This is the same EWG-style separation that keeps the research credible — stated here so there is no ambiguity.
Request a manual pilot audit
Free, in exchange for a testimonial and permission to publish an anonymized case study. Tell us about your line and we'll send you scope and timing. We read every submission ourselves.
Status
ClearSupply is in active development as Embr's independent services arm. The screening method is running now as manual pilot audits — the software that will automate it is the roadmap, not the requirement. We're taking a small number of pilots so we can go deep on each one. If a chemical-compliance question is keeping you up, email us directly.
Embr is an independent research publication on the chemistry of the sleep environment. ClearSupply is its firewalled services arm; paying for a pilot audit never influences any Atlas rating, Brand Emission Registry grade, or Sleep Environment Score. Regulatory dates are current as of July 2026 and move frequently — every client deliverable re-verifies date-sensitive items against primary sources. This page is informational, not legal advice.