Understanding Utah’s Online Sales Requirements: R70-101-13

Available July 15, 2024, Utah has released a copy of their new rule change regulating the online stuffed articles market. 

The proposed rules are available for public comment until August 14, 2024. Pending no changes, the rules may go into effect August 21, 2024, with an expected enforcement date starting April 1, 2025. 

It is important to note that these rule changes apply only to online sales. The requirements to attach a physical law label to products still apply.  

Listed below are the online sales labeling requirements for bedding/furniture and quilted clothing articles.  

3 Key Takeaways

1. By the expected enforcement date of April 1, 2025, all stuffed articles that are sold online and can be shipped to the state of Utah will need certain information available to the consumer online before purchase.
2. This information must be posted to each retailer’s product page, either listed directly on the page or hyperlinked to an approved third-party website like GRS’ Law Label Lookup™
3. This information can be made available as an image (a digital law label or digital textile label) or as text.

Utah’s New Requirements for Stuffed Articles

The following is required for stuffed bedding/furniture and quilted clothing articles that are sold online and can be shipped to the state of Utah.

Bedding and Furniture

Bedding and furniture products require a digital law label that lists:

• The product’s filling materials
• The product’s URN
• Any applicable sterilization permit number

Quilted Clothing

Quilted clothing products require a digital textile label that lists:

• The product’s filling materials
• The product’s RN/WPL — This must match the information presented to Utah during registration for a quilted clothing permit.
• Any applicable sterilization permit number

Made-to-Order Exemption

Made-to-order (MTO) products ordered in a brick-and-mortar location are exempt from the digital law label requirements.

Utah defines MTO as “a manufacturing process of upholstered furniture in which the production of an item begins after a consumer or retailer places an order and includes articles with consumer options that could impact the final law label.” 

We’ve confirmed with Utah that simply presenting prospective consumers with choices that could impact the label does not constitute MTO. 

Where Does This Information Need to Appear?

Retailers must list the required information on the product’s landing page, either:

Displayed directly on the product’s landing page. 

This may be in the product description section, product specifications area, image carousel, or another webpage location approved by the department.

OR

Hyperlinked to an approved third-party website like GRS’ Law Label Lookup™. 

Law Label Lookup™ collects your digital law labels and textile labels in one location, so you only have to manage one convenient URL rather than hundreds.

What is GRS Doing About Utah’s Update?

GRS is upgrading our technologies to pave the way for Utah’s text-only method, if you decide to move forward with that approach to satisfy the requirements. Vendors will only have to add filling material to their products through their GRS account.

However, our recommendation is to use digital law label / textile label images, uploaded to Law Label Lookup™. Law Label Lookup™ is an approved third-party solution that gives retailers peace of mind that their labels are fully compliant and verified to be free of errors.

Considerations for Image vs. Text

Utah’s law allows for the required information to be presented either as a digital law label / textile label image, or as text.

Here are some things to keep in mind when making the choice between image or text to satisfy Utah’s online sales requirements.

Text-Only Method

With text-only, vendors will provide the pertinent information to a company that manually enters the information to product description pages. There is no verification process for text-only, so if the information provided by a vendor is incorrect or non-compliant, it won’t get caught before getting uploaded.

The biggest consideration about the text-only method is that it opens up opportunities for human error that could put the products on your shelves at risk of violations and off-sales.

Product information is subject to frequent change due to changes in factory location, registration requirements, and filling materials. The companies that manage product description pages may not have access to the most accurate product information, putting your products at risk.

Retailers who choose to upload the filling materials and URN themselves may be taking on more work than they realize. Again, this information is subject to frequent change — and managing those changes across dozens or hundreds of suppliers with thousands of labels can quickly spiral out of hand.

Image Method

Uploading a digital law label or textile label image leaves much less room for error, and is the best way to keep your products in good standing with Utah regulatory officials.

For one, your digital law labels may already exist, and may already be uploaded to the GRS platform. Existing labels are ready to deploy without adding any extra work for your vendors that they would otherwise have to do for the text-only method. 

Law label images are a more comprehensive compliance solution that gives retailers better visibility into their suppliers’ labels. You can also choose to have GRS verify your law labels so they are completely free of error and fully compliant.

If you do decide to use the text-only method, GRS still recommends uploading a copy of the law label to the GRS platform for verification and visibility.

What Are The Next Steps for My Business?

GRS does not recommend taking action until Utah’s law is finalized. The updates described here are still open to public comment and may change.

As always, we recommend that manufacturers check with their GRS-partnered retailers to determine the path forward once Utah’s law is finalized.

Read the Update and Submit a Public Comment

Click here to read Utah’s update in full. The pertinent information starts on page 33 of the PDF, labeled page 29 on the bulletin itself.

The proposed rule changes are available for public comment until August 14, 2024. If you want to submit a public comment, contact information is listed below.

Questions? GRS Has Your Back

Our team is in daily communication with Utah and will update our customers as information becomes available. 

If you have any questions for the GRS team, we’re here to support you as the industry navigates these changes.