We are back from an informative and fun IABFLO industry conference held in Asheville, NC!
Highlights include excellent thought-provoking presentations, round table state reports on new initiatives, and a bit of fun touring the iconic Biltmore Estate and downtown Asheville (French Broad Chocolate FTW!)
Many of the state updates and initiatives have been reported in our previous newsletter, but here are some highlights worth noting:
This exclusive quick reference guide is available from the 2018 Manual of Labeling Laws.
We thank the Composite Panel Association (CPA) for allowing ISPA to publish this Quick Reference Guide, which CPA has prepared regarding the EPA’s formaldehyde regulation. This information is intended for use only as a guide to understanding these rules. Readers should consult with legal counsel for advice about specific legal or compliance issues. The views, thoughts and opinions expressed in the guide belong solely to CPA, and do not reflect those of ISPA or Legal Label. CPA has made every effort to confirm the accuracy of the information in this guide at the time of publication. CPA does not assume and hereby disclaims any liability to any party for any loss, damage, or disruption caused by any errors or missions contained in this information, whether such errors or omissions result from accident, negligence, or any other cause.
For further information about CPA, please visit its website at www.compositepanel.org
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What do you do when you’re ready to phase out a manufacturer?
At some point, you may decide you no longer wish to use a manufacturer. When this happens, there are certain steps to take to assure the states that you are doing your due diligence in shutting down.
When you stop using that manufacturer, you are discontinuing the URN. All products labeled with that URN will no longer be licensed in the states you let lapse. Even products that were previously registered and licensed will no longer be considered valid. So, should a product your company sells still be on the shelves of a store when you cancel the URN, there is a chance you could receive a violation for not being registered.
Violations can range up to $720.00. We advise you keep certain states that are stricter in violations for a year, as well as the base license. This will help avoid hefty fines.
In addition, when using a service like ours, you’ll need to let the states know that you’re giving us permission to cancel the plant. You should supply a signed Letter of Non-Renewal from the manufacturer that they no longer wish to use the URN. Legal Label provides these letters to clients who need them when closing out. If not, states will expect the license is still in use and request renewals for the manufacturer. In some cases, it can lead to confusion with other registrations.
For information on what states you should keep licensed, contact us.
San Francisco’s ordinance to ban flame retardants was unanimously approved on October 17th, 2017. It was sponsored by Supervisor, Mark Farrell of District 2 on the City and County San Francisco Board of Supervisors.
The ban goes into effect as of January, 1st 2019. Certain companies have been given an additional six months to comply. All other companies are expected to sell any and all “juvenile product or upholstered furniture” with less than “1,000 ppm of any flame retardant chemical”. The ban does not include children’s mattresses unless they meet 16 CFR Part 1632 or 1633.
Details are not currently available of how or if this will affect the California’s flammability label.
Need help with a flammability label? Contact Us.
Chemical Warning Requirements
Prop 65 Memo Available from the Law Offices of Joanne E. Mattiace
You may have heard that there are changes coming down the pike in regards to California Prop 65. Some of you have indicated great concern about these changes. To assist you with offering consumer products in California, we have prepared a short compliance document which can help you with your approach to such product offerings. Please let us know if you would like to order a copy of that memo.
Clients of Joanne’s law firm also get a 30 minute follow up with Joanne.
California Formaldehyde Law Label Example
US TSCA Title VI Compliant Law Label for EPA Formaldehyde Emission Standards for Composite Wood Products.
If your company offers any consumer product for sale which contains any type of manufactured wood, you are likely familiar with the need to comply with California’s wood and formaldehyde labeling and emissions standard.
Be aware that a new federal rule, both labeling and emissions, kicks in later this year. The new federal rule is similar, though not identical, to the California requirement. There has been a great deal of confusion over this federal rule but it is now slated to be effective in December of 2017. Companies may now begin to use the labels necessary to appear on products.
Now is the time to consult with your suppliers and secure documentation as to the emissions levels associated with the use of such manufactured wood in consumer products. Therefore, go ahead and begin to implement the new federal labeling requirements, and learn the new record keeping obligations imposed upon your company. Also, consult with legal counsel and/or the team at Legal Label sooner than later. Don’t put your product offerings at risk with a possible violation.