Annual Compliance Highlights

GRS Debuts New Website and Logo

The world of compliance for stuffed articles is complicated to navigate if you don’t have a helping hand. Global Registration Services is excited to announce a major update to our website that will make it even easier to navigate and take the actions you need for registration and compliance.

We hope you enjoy the better user experience with the new GRS website. Click here to see some of the highlights and new features that will make compliance more simple.

GRS and American Law Label Host Regulatory Panels

In October of 2022, GRS hosted a virtual Ask-the-States panel with state regulators from across the U.S. This event was a great way to hear from state officials about compliance pertaining to various stuffed projects, and to have stuffed article licensing and labeling questions answered.

Then in November, GRS and our sister company American Law Label, Inc. hosted a panel on hot topics in law labels. WE were joined by William L. Troutman of Norton Rose Fulbright for a refresher on law label requirements, and a discussion on enforcement trends, labeling of recycled fill, and other regulatory insights.

Ohio Testing Process Changes

As of 2022, Ohio will no longer conduct testing of regulated bedding, upholstered furniture, or stuffed toy products that contain blended fiber materials.

Sample testing will still be required by the Ohio Department of Commerce. Testing will now be outsourced to third-party laboratory agencies and a sample analysis will have to be submitted with an Ohio new registration application. GRS has partnered with IDFL for sample testing of single and blended fibers.

If you aren’t working with GRS, Ohio has posted a list of approved third-party agencies on their website. We anticipate that more agencies will be included on the list in the future. If your product contains a single filling material, you can still submit samples directly to Ohio’s testing laboratory.

GRS Institutes Importer Table Requirements

In the past year, GRS has seen an increase in states enforcing and issuing more violations for improper importer / distributor licensing and law label wording.

To assist our customers and get ahead of state violations, in September 2022 we instituted required importer tables for companies that have blanket licenses. This will help companies who are importing / distributing products to improve their licensing and labeling practices.

CPSC Creates 16 CFR 1241 Standard Requirements

The U.S. Consumer Product Safety Commission (CPSC) has issued an updated guidance on 16 CFR part 1241, Safety Standard for Crib Mattresses. The standard became effective on August 15, 2022.

This updated guidance provided expanded responses to frequently asked questions and a table to assist crib mattress manufacturers and importers in understanding which requirements apply to their products. The requirements of 16 CFR part 1241 are in addition to other mandatory requirements already in place for the subject products, as applicable.

To view the updated guidance, please visit their website.

Walmart Converts to Retail Compliance Program

Global Registration Services discontinued the Vendor Certification program in February, 2022, and transitioned all Walmart suppliers into our Retail Compliance program. This improved platform includes license storage and expert verification, automatic renewal reminders, and priority support from the GRS team.

Under the new program, companies testing with Walmart are required to subscribe to the Retail Compliance program as well as one of our three Monitored Service subscriptions.

Quebec Revokes Regulation
Effective December 2021, the Canadian province of Quebec has repealed its Act pertaining to stuffing/upholstered and stuffed articles. Product fill and products with hidden stuffing are no longer required to be licensed in Quebec. Products with hidden stuffing (e.g., upholstered products and stuffed toys) are no longer required to be labeled.

If you hold a license in Quebec, you can safely allow it to lapse. Going forward, Quebec will no longer be issuing new or renewed licenses.

For our customers who have licenses under our management, our team will be in touch in the event that unpaid monies due to Quebec have yet to be remitted. Our team is working to identify and issue refunds in the most efficient and effective manner.

If you are a Retail Compliance customer, your Quebec licenses will no longer need to be uploaded into our system for verification. We will be in communication with our Test Lab and Retail partners to ensure this process is adjusted accordingly. In the event your product is failed due to a missing Canadian label and/or license, please contact our team.

Please keep in mind that although provincial requirements have been repealed, Canada requires labeling that includes manufacturer and fill information. This label may be combined with care instructions. If you have questions about formatting or updating your Canadian labels, please contact our labeling expert at American Law Label, Rick Pritchett:
rpritchett@americanlawlabel.com

SOFFA Federal Flammability Standard
In December 2020, the Congress passed the Safer Occupancy Furniture Flammability Act (SOFFA) which requires manufacturers to adopt California’s TB 117-2013 as a federal flammability standard for residential upholstered furniture (mattresses excluded). California’s Technical Bulletin 117-2013 (TB 117-2013) outlines standards and testing methods, smolder resistance of cover fabrics, barrier materials, and resilient filling materials in upholstered furniture.

SOFFA will require manufacturers to comply with the TB 117-2013 standards and upholstered furniture must bear a permanent label that includes the statement “Complies with U.S. CPSC requirements for upholstered furniture flammability”.

SOFFA’s effective date was originally set for June 25, 2021. Manufacturers should start preparing their labels to be compliant with the standard. For more information, please read this article. If you need your law labels updated, American Law Label can assist you!


SOFFA Requirement Update
The deadline for correctly labeling furniture under SOFFA labeling requirements was extended until June 25th, 2022. The new standard is 16 CFR 1640. However, all upholstered furniture was still required to be tested to the TB117 standard before June 25th, 2021 if not previously tested. The direct final rule can be seen here.


Federal Rule for Infant Sleep Products
The Consumer Product Safety Commission (CPSC) voted to approve a new federal standard that is intended for products marketed for infant sleep to ensure a safe sleep environment for babies under 5 months old.

The standard will “eliminate potentially hazardous sleep products in the marketplace that do not currently meet a CPSC mandatory standard for infant sleep, such as inclined sleepers, travel and compact bassinets, and in-bed sleepers.” It will require products that do not meet current sleep standards to be tested to confirm that the “angle of sleep surface is 10 degrees or lower.”

Products that fall into this category will be expected to meet the federal standard beginning in mid-2022. For more information, please visit the CPSC’s website.


Quilted Clothing Labeling Requirement
Effective January 1, 2022, a sterilization permit number is required on the textile label for some quilted clothing when it is offered for sale in the State of Utah. This includes any item with filling material of animal origin, like wool, shoddy, down and/or feather.

According to the State of Utah’s Bedding, Upholstered Furniture, and Quilted Clothing Inspection Act, “‘quilted clothing’ is defined as a filled garment or apparel, exclusive of trim used for aesthetic effect, or a stiffener, shoulder pad, interfacing, or other material that is made in whole or in part from filling material and sold or offered for sale.”

A US law label is required if quilted clothing is sold in Utah and must include the filling materials and percentages. If it contains down or feathers, the sterilization permit of the company that did the sterilizing must be listed on the law label. A quilted clothing permit must also be acquired in the state of Utah. The quilted clothing permit and sterilization permits are separate from the bedding and furniture permits we typically assist customers with.

Apparel law labels are also required for clothing in the Province of Quebec. Canadian law labels must list French and English on the law label. US and Canadian law labels are completely different, so two law labels are required to be attached if the product is being sold in both countries. Labels must be placed conspicuously on the clothing so consumers can easily read them prior to purchase.

California TB117 Labels
As of January 1, 2020, the state of California prohibits the sale and distribution of juvenile products, upholstered furniture, replacement components of re-upholstered furniture, and the foam in mattresses (collectively referred to as “covered products”) that contain covered flame-retardant chemicals at levels above 1,000 parts per million (ppm).

All TB117/SB1019 labels attached to products must have the box checked that indicates NO flame retardant chemicals have been added. California now requires that “California Bureau of Electronic and Appliance Repair, Home Furnishings and Thermal Insulation” be changed to “California Bureau of Household Goods and Services” on the TB117 labels.


Manitoba Revokes Regulation
In light of Ontario’s revocation of their bedding regulation, the Government of Manitoba repealed their Bedding and Other Upholstered or Stuffed Articles Regulation, effective January 1, 2020.

Ontario Revokes Regulation
Effective July 1, 2019, Ontario no longer requires manufacturers to pay and maintain their upholstered, bedding, and all stuffed article licensing for the province of Ontario.

The official bulletin states: “Upholstered and stuffed articles sold in Ontario will continue to be subject to applicable federal legislation including the Canada Consumer Product Safety Act and the Textile Labelling Act, as is the case in other provinces. In addition, the Toys regulation under the Canada Consumer Product Safety Act has additional requirements for stuffing in dolls, plush toys and soft toys (i.e., must be clean, free of vermin, free of hard or sharp foreign matter, non-toxic and non-irritant).”

To read the full bulletin, please click here.


Pennsylvania Fee Increases
The Pennsylvania Legislature, under House Bill 118 (Act 40 of 2017), approved fee changes for the Bureau of Occupational and Industrial Safety on October 30, 2017. All licensing fees for manufacturers and importers of new bedding & upholstery and stuffed toys, sterilization factories, auctioneers, and secondhand retailers of bedding & upholstery were affected.

Per Act 40 of 2017, the fees associated with our bureau are tied to the Consumer Price Index (CPI). Due to the CPI’s increase of 1.4%, all fees for the Bureau of Occupational and Industrial Safety increased and became effective on October 26, 2019.

Please note that Pennsylvania fees increase every year. The new fees are released in late October or early November, and go into effect from December to December each year.