Pending Legislation: Utah Visibility Requirements Webinar Postponed

GRS’ upcoming Utah Visibility Requirements webinar discussing the state’s digital labeling requirements has been postponed due to pending legislation. 

While Utah's bill S.B. 231 is not guaranteed to be signed into law, it would have implications for stuffed article regulation in the state. Here’s what we know so far.

S.B. 231 Explained

S.B. 231 Bedding, Upholstered Furniture, and Filling Material Amendments is a bill that was introduced in the Utah legislature in early February 2025. 

Chiefly, in regards to stuffed articles, the bill “repeals permitting and registration requirements” and “removes certain tagging or similar requirements administered by the Department of

Agriculture and Food for bedding, upholstered furniture, and filling material.”

In short, S.B. 231 would dissolve Utah’s Bedding, Upholstered Furniture and Quilted Clothing Program, meaning Utah would no longer regulate stuffed articles in any way. That means that outside of federal regulations, Utah would not require any of the following to sell stuffed articles in the state:

• Registration
• Permits (Licenses)
• Labeling or Tagging
• Fees
• Renewals

If passed, the bill would go into effect on May 7, 2025. You can read the full text of S.B. 231 here.

The Costly Implications of S.B. 231

While we believe that stuffed article regulation is an important protective measure for consumer safety and confidence, we also believe that Utah’s Program is a uniquely important vehicle for bringing products to market in the United States.

Importantly, Utah provides:

• Joint Licensing, which puts more control in the hands of importers
• A very quick registration process
• A uniquely fast and direct path to bring stuffed articles to market across the U.S.

Joint Licensing: Empowering Importers

First, Utah is one of only three states that offer Joint Licensing. A Joint License offers importers ownership and oversight of the registration process, the license itself, and renewals to ensure their product remains compliant. 

Companies that import and distribute stuffed articles here in the U.S. often prefer Joint Licenses. They are a particularly powerful incentive to do business in Utah.

Registration Turnaround: A Great Benefit for Businesses

Another unique advantage is Utah’s quick registration process. On average, Utah reliably issues a Joint URN within 5–7 days. That quick turnaround time allows law label design, printing, and affixation to products to begin while the company awaits registration in the remaining regulating states. 

A job that starts with a Utah URN is consistently completed within one month of starting the registration process. This is the quickest possible path to market while providing the added assurance of Joint Licensing. In comparison, the next fastest state that issues Joint Licensing is Pennsylvania with a 500% longer waiting period to issue a URN (from 5 days to 30 days).

With Joint Licensing and its expedient path to market, Utah’s Program represents a unique opportunity for retailers, their suppliers, and consumers across the country. As a leader in compliance and a trusted partner to thousands of stuffed article businesses, GRS urges the state of Utah to oppose S.B. 231 and keep its Bedding, Upholstered Furniture and Quilted Clothing Program intact.

S.B. 231 Spells More Headaches for Businesses

Every business that sells products to consumers in Utah have already done the due diligence of getting compliant with the state. S.B. 231 would punish those businesses with even more sunken costs, time, and effort to re-achieve compliance.

Each company would be required to undertake the time-consuming process of:

• Re-registration, which comes with additional administrative costs and hoops to jump through
• Re-labeling, which could cause extensive delays in returning their products to the marketplace

Re-Registration

In the event that Utah ends its bedding and furniture program, every manufacturer (and every importer in the case of Joint Licensing) with a Utah URN would be required to re-register with all other regulating states, which can add up to 14 required licenses total depending on the product type.

These re-registrations would cost businesses thousands of dollars in state fees, not to mention third-party processing fees for registration support. That's on top of the lengthy, 40 to 70-day process of obtaining the full set of licenses, workshopping with each state to explain the cause of re-registration, and tackling other administrative burdens.

Re-Labeling

Another important consideration is the fate of the products bearing Utah URNs that are already on shelves across the U.S. 

Many state agencies have strict regulations prohibiting labels from containing false, untrue, or misleading statements. If Utah were to discontinue its bedding and upholstered furniture program, any product currently labeled with a Utah registration number would require immediate re-labeling.

This would have to be solved by one or more of these costly solutions:

• Replacing labels through the cut-and-sew method is extremely costly, labor-intensive, and disruptive to supply chains. Many domestic warehouses do not have the equipment or workforce to perform this type of modification, and would require shipment back to the original manufacturer, often located overseas, for relabeling. This process introduces increased transportation costs, extended lead times, and potential customs delays.
• Amending labels by affixing a corrective adhesive label requires pre-approved materials that are costly to procure and are subject to supply shortages. Additionally, six state agencies require a lengthy documentation process which includes contacting state officials, identifying their specific requirements, submitting label samples, and providing paperwork. This includes applying for an official Ohio variance, which is required when a product's label no longer accurately reflects the original product that was brought to market. Furthermore, receiving adhesive law label approvals can take 2-12 weeks, potentially delaying shipments and causing manufacturers and importers to miss retailer deadlines—resulting in financial losses of thousands of dollars.

There's one major wrench in this re-labeling plan: adhesive labels and variances are not guaranteed per written state laws. The other regulating states can at any point decide not to allow these methods of correction. This would leave cut-and-sew as the only remaining option.

It's clear that S.B. 231 would only add more costs and administrative burden to the already complex process of bringing stuffed articles to market in the U.S. If you would like to contact Utah regarding the bill, you can use the contact form here. Select Senator Brady Brammer from the drop-down menu, as he is the senator that introduced the bill.

The Current Roadmap

Since the introduction of S.B. 231, things are in a holding pattern in Utah. The state is currently still offering registrations and performing inspections of stuffed articles on store shelves.

As we understand it, there are two likely scenarios: one in which S.B. 231 is signed into law, and one in which it is not.

If S.B. 231 Passes

In the event that S.B. 231 is signed into law, we have developed an action plan to keep those with Utah URN-issuing licenses compliant. We will share details about that plan should S.B. 231 continue through the Utah legislature.

If S.B. 231 Does Not Pass

If S.B. 231 is not signed into law, business will continue as usual in Utah. They will continue to accept registrations, issue URNs, and provide a quick path to putting stuffed articles on shelves.

Next Steps

GRS is already involved in discussions with Utah legislators and industry partners surrounding S.B. 231 and its implications for stuffed article regulation in the state.

We will continue to keep our customers informed about Utah’s decision as this story develops. If you have questions for the GRS team, please tap the button below to get in touch.