Does your company produce, or import, any products with manufactured wood components? (Think adjustable bases or furniture pieces among other products.) If so, then you should become familiar with the Environmental Protection Agency’s final rule regarding formaldehyde emissions associated with manufactured wood such as particle board, plywood and the like. New label obligations as well as compliance with emissions standards become effective in 2017, meaning that each company needs to carefully consult with its wood suppliers and assess very soon whether a redesign of its products is necessary. Moreover, record-keeping requirements will soon be imposed upon each company in the stream of commerce. CONTACT Ms. Mattiace for additional information at 1-877-481-0734.
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Laws and Regulations
IMPORTANT Massachusetts Policy Changes
Massachusetts is currently reviewing their bedding, upholstered furniture and stuffed toy regulations and has determined that in accordance with M.G.L C. 94, § 271 and/or 105 CMR 620.000 they can require licensing per manufacturing location, just like the rest of the states currently do. Their past interpretation of allowing one license for all of a company’s manufacturing facilities will no longer be allowed, and upon renewal will require a separate application per facility for a fee of $300.00 for each license.
The Importer or Wholesale Dealer must be licensed if the manufacturer is not.
Legal Label is working with MA to ensure proper licensing for each of our clients.
Please note, MA has changed their expiration dates for all new licenses to one year from date of issue (as opposed to 6/30 annually.)
If you need help understanding these changes please contact Legal Label.
U.S Senate Updates Legislation
Toxic Substances Control Act (TSCA)
The U.S. Housed passed a bill to update the TSCA, which governs the use of chemicals in consumer products, followed by the U.S. Senate unanimously passing the legislation, and will soon be sent to President Obama, whom is expected to sign this update into law.
This legislation includes a “grandfather” provision allowing state chemical laws or regulations that were already in place before 4/22/2016, (such as CA’s Prop 65) to remain in place. States will still be able to target specific chemicals, but the EPA will preempt any previous action that as occurred after 4/22/2016. Pending actions will need to wait for EPA review. This may take several years to be able to implement this new legislation. ISPA will be involved with this work and will provide updates. More from ISPA
Pennsylvania Variance
Do you know that PA requires a variance for any term not listed in their regulations?
Even if you have an existing license, if you’re using terms on your law label that are not listed in the Pennsylvania Regulations, you need to file a variance application. Some of the common terms that require a variance are:
- Batting
- Blended Fiber Batting
- Cotton (by itself)
- Olefin
- Pad
- Polypropylene Fiber
- Polystyrene Foam Beads
- Resonated
- Visco Elastic
If you’re not sure if your terms are accepted in PA, or if your law label has changed since your initial application, contact us for help with this complicated requirement. It’s always a good idea to have us periodically review your law labels to ensure they are still in compliance with changing regulations. CONTACT US