International Association of Bedding and Furniture Labeling Officials
This page is for information purposes only. IABFLO strives to help regulators and industry for uniformity as it pertains to Law Labels. The company remains responsible for compliance with the laws regardless of anything stated or not stated by IABFLO. These statements are not considered legal advice.
|Can a polyurethane “memory” foam pad list both polyurethane and viscoelastic polyurethane on the law label, or would it need to be labeled just as polyurethane?||
Both labels would be acceptable as long as the claim is accurate. For example you can list either:
POLYURETHANE FOAM PAD……………100%
POLYURETHANE FOAM PAD…………………………………..67%
VISCOELASTIC POLYURETHANE FOAM PAD………………33%
If multiple factories are completing the manufacture of identical products, can I list multiple registration numbers on one law label to be used for all the products?
|No, each manufacturer must be registered, and the labels for products manufactured by that manufacturer must have the registration number of that manufacturer, and only that manufacturer. Using multiple registrations on one label is not acceptable.|
|In the “Name and address of Manufacturer, Importer, Distributor or Vendor” section of the law label, can the wording “Made Exclusively for” be used?||The wording “Made Exclusively for” may be used in the USA as long as the manufacturer, importer, and distributor are licensed. In Québec, this wording may NOT be used in the “Name and address of Manufacturer, Importer, Distributor or Vendor” section, however, it can be used at the bottom or beside the law label.|
For labeling purposes, who is considered the manufacturer?
|Whoever provides the final stitch is considered the manufacturer.|
|Which states require the “Date of Delivery” portion of the law label?||CT, MA, RI and the City of Detroit require “Date of Delivery ” information to be included in the “other information section,” but we are informed that these jurisdictions at present do not enforce this requirement.|
|Can the “Date of Delivery” be considered the same as the date of manufacture?||No|
|Can the words “For US customer only” be placed on the law label by the “Made In” portion?||No|
|Are flammability tests required for labeling purposes?||California is the only state that requires flammability testing. All upholstered furniture that is offered for sale in California must meet the TB117 flammability standard (As of January 1, 2015, must meet TB117-2013). A law label and compliant flammability label must be attached to these products. TB116 is a voluntary smoldering standard, however if you label your product as compliant with the TB116 you must meet the requirements. All mattresses and mattress sets must meet the Federal standard, 16CFR1632 and 16CFR1633 and mattress pads must meet the 16CFR1632. A law label and appropriate Federal labeling must be attached to these products.|
|Can I place a SKU number on the label?||Yes, but it must be placed on the bottom of the label and be separated from the rest of the label by a bold black line that extends the entire width of the label.|
|Can I place a logo, barcode, or care instructions on the label?||In the USA, trademarks, logos, and care instructions are NOT allowed on the law label. A barcode may be placed on the tag but it must be placed below the label and separated by a heavy black line that extends the entire width of the label. In Québec, a logo and care instructions can be included on the tag as long as a heavy black line separates them from the law label.|
|Can any part of the law label be handwritten?||No|
|Can I place a reproduction of the law label on the products packaging?||
Yes, but it must be an exact replica of the law label. This is a requirement in Virginia, Utah, and Texas if the product label is obscured by the packaging.
When labeling a product that consists of multiple filled components, can a label be placed on only one component that lists the fillings of all the components?
|As long as none of the components are offered for individual sale and the label with all of the fillings is attached to the main component, this is acceptable.|
When selling a product that has multiple components, but is being sold as one unit, is it necessary that one of the components is labelled as “BODY”?
|In these cases, each individual component should be labeled separately.|
|If the label on the product is obscured by the packaging, can white tape with the law label printed on it in black ink be used on the packaging?||Yes, as long as it is black on white and is an exact replica of the law label attached to the product.|
|Are adhesive law labels acceptable for replacement parts for wheelchairs that do not have a seam to attach a law label to?||Yes|
|Are there any labeling requirements for “foam only” bedding products like a foam egg shell topper, where the foam is sold alone without any covering or fabric?||
Yes, many states require this type of product to meet labeling requirements (and flammability requirements in CA). The labeling for these products may be placed on the packaging if the product cannot support a securely attached law label.
|Are disposable pillows required to have a uniform law label?||Yes, disposable pillows are regulated as filled bedding products and require all the same registrations, labels, etc.|
Do a padded mechanic’s roller seat and padded mechanic’s creeper require a law label and registration?
|The following states require these items to have a law label and the manufacturer must be registered: Connecticut, Massachusetts, Ohio, Utah, and California. In California these products must also meet flammability requirements and have a flammability label attached.|
|Do any states require the testing and labeling of pet beds?||Yes. If the pet bedding has filling material, Ohio requires the manufacturer to be registered and the products are required to be tested and an approved label attached. Ohio rescinded this portion of their code during their 2017 legislative session.|
|Are pool toys that have a filling material considered bedding and do they need the same licensing, registration, and labeling?||Yes.|
|Do products similar to the following need a uniform law label?||
In the USA, items like the above would not be regulated as a filled item. In Québec, this item would be regulated and would need a uniform law label.