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When You No Longer Use a Manufacturer

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.

IABFLO Conference 2016, Re-cap

This year’s IABFLO conference, held at the Wyndham Philadelphia in historic downtown from April 19-22, was a great success. A shout out to President Michelle Jack of Utah, Richard Selegue of Ohio, and Kay Harris of North Carolina for all their hard work in organizing this conference.

We were happy to see that Pennsylvania has rejoined IABFLO and that the City of Detroit sent their bedding program administrator, Lisa Clark Jones.

This year Ikea was kind enough to give us a tour of their DC unit in New Jersey; an impressive example of warehouse management and technology on a massive scale.
This was followed by a fabulous industry dinner, courtesy of DuPont and Print Craft at Pietro’s Italian Restaurant and was greatly appreciated by all.

We spoke with a number of conference attendees, including Speakers Kathy Manderino, Secretary of the Pennsylvania Department of Labor & Industry, Joe Mohorivic of ISPA, Dr. Pratik Ichhaporia of Intertek, Dr Heather Stapleton of Duke University, Joanne Mattiace of the Law Offices of Joanne Mattiace, Wilf Lieber of IDFL, Ryan Trainer of ISPA and Christina Slaybaugh of Pennsylvania. Copies of their presentations will soon be available on the IABFLO website for members.

During the round-table we heard from some State Regulators of upcoming changes. These included the following:


California: expect to see the license fees go up, possibly as soon as October of this year. The proposed fees will be as follows:

Bureau’s current and proposed fee for each license type.

Section 1107(a) Subsections and License Type    Current Fee    Proposed Fee
Importer’s License $650 $750
Furniture and Bedding Manufacturer’s License $650 $750
Wholesale Furniture and Bedding Dealer’s License $540 $625
Supply Dealer’s License $540 $625
Custom Upholsterer’s License $360 $420
Sanitizer’s License $360 $420
Retail Furniture Dealer’s License $120 $140
Retail Bedding Dealer’s License $120 $140
Retail Furniture and Bedding Dealer’s License $240 $280

 

Additionally in 2017 they will develop a rule making packet to update the law label and the terminology in their classification of filling materials. Prior to the formal rule making proceeding, California officials have indicated a willingness to receive and consider written comments regarding possible future action.

If you wish to receive updates on this matter and other Bureau activities please subscribe to their LISTSERV.

Lastly California mentioned that now that TB117-113 SB1019 has been instituted for a period of time you can expect to see more inspections looking specifically for compliance with this flammability regulation.


Connecticut: is now inspecting secondhand dealers and they are starting to issue major financial fines against dealers for not sanitizing properly. They also warned that if these corrections are not addressed then the company who does not comply stands to lose their Secondhand Dealers License and will be unable to operate their store without one.


Detroit MI: The bedding program coordinator, Lisa Clark Jones joined IABFLO this year. Detroit is planning on ramping up their program so you can expect to see change including more enforcement in the year to come.


North Carolina: Kay Harris spoke about the licensing backlog, dealing with employee absence, and how they have been working on getting these licenses out.


Ohio: Richard Selegue and Derrick Hubner informed us that Ohio has bought new pieces of equipment, including a new Thermo Scientific Nicolet FT-IR and also a new compound microscope. This will be a significant assistance in being more efficient and hopefully move samples through more effectively.


Pennsylvania. Spoke of how AP has rejoined IABFLO and how they will review their regulation in the coming months in terms of requirements for variances.


Utah: UT State legislature has approved a Sterilization Permit requirement for clothing and bedding. Currently this is in the documentation process for rules/guidelines and may be effective in 2017.


 The 2017 IABFLO conference is scheduled in Newport, Rhode Island from April 26-27.