Product Label Guidance

The American Home Furnishings Alliance, the parent organization of ICFA, has updated its “Anatomy of a Law Label” guidance to include the new federal flammability regulation compliance statement. The statement will be required on law labels for all upholstered furniture manufactured domestically or imported on or after June 25, 2021.

The federal flammability regulation made its way into law late last year as part of the year-end omnibus spending bill. Originally called the Safer Occupancy Furniture Flammability Act – or SOFFA – the law was renamed the “COVID-19 Regulatory Relief and Work From Home Safety Act” and signed by President Trump on December 27.

The regulation requires the U.S. Consumer Product Safety Commission (CPSC) to adopt California’s Technical Bulletin 117-2013 as a federal flammability standard by June. While the federal rule calls for no changes in the smolder test procedures for upholstery components outlined in TB 117, it does require a new compliance statement on the law label. The new statement is:

Complies with U.S. CPSC requirements for upholstered furniture flammability.

For upholstered furniture sold outside California, this statement should be used in lieu of the California TB 117-2013 compliance statement.

For upholstered furniture sold IN California, both the CPSC and the California certification statements are needed, according to officials from the California Bureau of Household Goods and Services (BHGS), which oversees TB 117-2013 enforcement. Diana Godines, policy manager for the California BHGS, addressed the issue during an AHFA members-only webinar last week.

Godines said California could decide to adopt the CPSC compliance statement at some time in the future. However, she advised that amending TB 117-2013 to accept the statement would take a minimum of 24 months.

She also emphasized that, in addition to both flammability compliance statements, the law label on upholstered products sold in California also must continue to include the flame retardant content statement required by California SB 1019.

To simplify labeling procedures, furniture sold outside California also can include both the CPSC and the California compliance statements.


Sample labels with the federal flammability compliance statement alone, as well as the federal statement combined with the California statement, are shown in AHFA’s updated “Anatomy of a Law Label” document, found in the Member Toolbox at AHFA | American Home Furnishings Alliance. You must have an AHFA member login to view this document. If you need one, please contact Jackie or Michele.