Labels


Products need to carry certain labels if they are to be offered for sale legally in the United States.  Below follows some of the highlights of those label requirements.

Law Labels:

In the early 1900s, states began passing “tagging laws” which required that bedding products carry labels identifying their hidden contents in order to protect consumers. These labels soon became known as “law” labels. You have probably seen this label on your mattress or bed pillow and laughed over its dictate that it is “Not To Be Removed Under Penalty of Law.” You may have even wondered about label police visiting you at home!  These laws and the labels that they mandate are intended to protect consumers from unknowingly purchasing a second-hand product containing unsafe or unsanitary materials. The laws also have served to protect reputable manufacturers from unscrupulous ones, since they mandate the use of labels which describe the hidden material content of the product.  Unscrupulous companies use such labels at their own risk when the materials used are not as described on the label. State regulators engage in retail inspections to see if products carry the required labels. Stop Sale and Notice of Violations can ensue if those labels are incorrect.  Monetary penalties are also possible.

Law labels are white if the hidden materials used within the product are new. Law labels are typically yellow or red if the hidden materials are used and the product is considered “secondhand” or renovated. In some states the law labels must also contain detailed information that the product has been sanitized. Rental companies in particular need to be aware of these label rules. Secondhand bedding offerings must comply with a number of very detailed state and local regulations.  Contact us for details. This is particularly important that renovated mattresses, for example, need to abide by  strict new federal flammability rules.

The requirements for law labels are quite detailed and some state requirements differ from other states.  We here at Legal Label can help you create one label that satisfies all the states requirements.  We tell you if other paperwork is needed to be filed with the various states.

Flammability Labels:

Regardless of a state’s law label requirements, the federal government, by way of the U.S. Consumer Product Safety Commission (CPSC), mandates that mattresses and mattress pads offered for sale in the United States bear certain flammability information. These requirements are typically referred to as “1632” and “1633,” shorthand for 16 CFR 1632 and 16 CFR 1633. These labels must attest to the product having passed stringent fire tests.  In addition, recordkeeping of the testing is required.

Flammability rules are complicated and fire testing is expensive, so these labels are often a company’s first line of defense. A poorly executed label may lead to a product being pulled from retail. An expensive recall of product might then be ordered.  Check with us to be sure that you have fulfilled your flammability obligations!

California Flammability Requirements, Technical Bulletins 26, 116, 117, 121, 129 and 133 and more to come.

Since 1975 the California Bureau of Home Furnishings and Thermal Insulation has developed several flammability standards that apply to certain products.  These requirements are contained within the state’s “Technical Bulletins.” These are mandatory requirements and are in addition to CPSC mandates. If your company offers bedding or upholstered furniture pieces in the state of California, regardless of where it may have been produced, it is essential that you be sure that they pass the flammability criteria put forth by California and that they have the appropriate labels. Failure to do so can result in “stop sale” orders and substantial fines.

Legal Label can assist you with your California obligations.  Contact us for details. Even if you have not yet tested your products, we can put you in touch with a reputed testing facility. Don’t wait until after your product has been designed and produced. 

Note that California (and some other states) is working on establishing flammability requirements for top of the bed items such as comforters, quilts, and pillows. And, as California goes, so does the federal government!  Federal flammability rules are also being developed for such top of the bed items.  Whether California (or another state) beats the federal government with a new flammability requirement for such products, this much will likely be true: new labels will be required.  Keep that in mind.

Federal Furniture Flammability: Pending

Flammability requirements for upholstered furniture pieces are currently under development at the federal level.  Expect detailed requirements as to same, including more label requirements and more recordkeeping.

Children’s Products

Both federal and state requirements apply to the marketing of children’s products and these regulatory requirements are numerous.  Failure to carry the appropriate label on a child’s product may easily cause it to be pulled from sale, perhaps even recalled.  We can furnish details.  Contact us for a free consult. Now, more than ever, these issues matter.  Don’t ignore them.

Textile:

Textile, wool and fur products need to carry specified (and permanent) labels that must remain legible throughout the life of the product. The label requirements apply to manufacturers, importers, and retailers. In general, most clothing and textile products commonly used in a household are covered by the labeling requirements.

Care Instructions:

The Care Labeling Rule requires manufacturers and importers of textile wearing apparel and certain piece goods to attach care labels to these items stating what regular care is needed for the ordinary use of the product. The Rule also requires that the manufacturer or importer possess, prior to sale, a reasonable basis for the care instructions.

Bedding Products, Children’s Products and Textile

All consumer products need to carry information that serves to inform the consumer about the product they are buying. This is required by law, in some instances by the federal government and in other cases by the states.  When the federal government and several states require different pieces of information to appear on the label, confusion and frustration can easily result.
In order that a product may be lawfully offered for sale, it must be labeled correctly.

Manufacturers, distributors, importers and retailers each share the responsibility to offer properly labeled products.

Legal Label’s mission is simple.  We assist companies with their labeling and registration responsibilities. Our specialty is that of bedding products (mattresses, futons, pillows, comforters, quilts and the like) and their need for law labels, flammability labels, textile tags, and care instructions. Contact us at Legal Label Inc. to review your products and determine what labels are required so they may be offered for sale.

Many states require labels on a long list of products.  Some of those states require both such labels AND require advance registration of the manufacturing facility. Finally, in some instances, an importer must additionally register.  The manufacturer’s registration does not suffice.

An even broader list of products requires what is known as a “textile tag” as well as Country of Origin disclosure.  In addition, care instructions must be provided for many of those products.  Items such as clothing or general wearing apparel, blankets, pillows, furniture pieces, and flags need labels that provide identification of the manufacturer, the country in which it was made, and a description of its fiber content. If an item is made of wool, other rules apply.  Fur products also fall within a special subset of labeling rules. Contact us at Legal Label Inc. to review your products and determine what type of labels are required to sell your product to the consumer.

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