US Law Label Requirements For Importers: A Complete Guide

US law labels are mandatory for stuffed products in most US states. Such products can include beddings, stuffed toys, bean bags, and other stuffed products. The purpose of a law label is to inform the consumer of the filling material.

However, what makes this requirement somewhat complex is that law labels are regulated on a state level. Hence, the product scope, labeling, and registration requirements differ between states.

Methodology: This guide is primarily based on law labeling requirements in California, under Home Furnishings and Thermal Insulation Act Rules and Regulations.

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What is a US Law Label?

The US Law Label dates back to the early 1900s and requires that the filling materials of certain products are specified. In other words, the consumer should know what’s inside a product

This includes filling materials in pillows, mattresses, sleeping bags, and other textile products. Here’s an example: Polyurethane Foam 90%, Blended Cotton Felt 10%.

Example (California)

• “Do not remove” statement
• “All new material” statement (for new products)
• Description of filling material
• Registry number
• Certification statement
• Finished size (only for some products)
• Net weight of filling material (only for some products)
• TB 117-2013 statement (only for bulk filling material)
• Name and address of vendor or manufacturer (optional)

Is the US Law Label mandatory?

Yes, if you sell in one or more US states that require law labels for certain products.

Which US states require a Law Label?

Here are some states in which the US Law Label is required:

• California
• New York
• Illinois
• Ohio
• Texas
• Virginia
• Arizona

American Law Label Inc mentions that law labels are required in more than 31 states.

Which products require a US Law Label?

Generally speaking, products with filling materials require a law label – but the exact product scope differs depending on the state.

Here are examples of products that require law labels in California:

• Articles of upholstered furniture without loose cushions
• Decorator pillows
• Chair cushions
• Quilted
• Bedspreads
• Headboards
• Hassocks,
• Articles of furniture with loose cushions
• Articles of bedding
• Bed pillows
• Comforters
• Mattress pad
• Sleeping bags, pads, mattresses

Law Label contents

The exact contents of the law label depend on the state. This is an example listed as Type No. 1 in California’s HFTI Laws and Regulations:

Uniform Law Label

Businesses often sell in more than one state, which can make it difficult to keep track of differing law label content and format requirements. One solution to this problem is to create a Uniform Law Label – which covers requirements in all affected states.

The International Association of Bedding and Furniture Labeling Officials (IABFLO) provides guidance and examples for several types of Uniform Law Labels:

• Beddings and furniture
• Filled clothing
• Feather and down
• Stuffed toys

Uniform Registry Number (URN)

In New York, California, Texas, and other states, manufacturers register and include the registration number on the Law Label. However, the registration number is only obtained from one state, and can then be used for registration in other states.

As such, you will not need a unique registration number for each state you sell in.

Can I use the supplier’s URN?

Importers can sometimes use the manufacturer’s URN. That said, don’t expect the average supplier on Alibaba.com to have a URN. Most non-US suppliers are not even aware of URNs or how to register. Hence, it is likely that you as the importer must take care of law label creation, and registration.

Where should the Law Label be placed?

In California, the law label should be permanently affixed to the product in an area where it is easy to find. However, they do not provide any specific examples beyond that.

Keep in mind that the law label should not be placed on a sticker or hang tag that is not permanently affixed to the product. Likewise, it is not sufficient to affix the law label to the product packaging, or user instructions.

Are Law Labels required for imported products?

Yes, law labels are also required for products that are imported from other countries. For example, if you manufacture sleeping bags in China for sales in California, then these must come with a law label.

In practice, this means that you must provide a ready-made label file, complete with the registration number and other information.

Label Information

In addition, you must also provide the supplier with the following:

• Dimensions
• Placement
• Material
• Color

Foreign manufacturers

Do not assume that manufacturers outside the United States are even aware of the Law Label. It’s up to you as the importer to provide the label and clear instructions.

Further, you must also verify that the product is correctly labeled during the pre-shipment inspection.

Filling materials

The label must include an accurate description of the filling materials. If you’re importing custom-designed products, you should always include this in the Bill of Materials. If you’re buying a private label product, on the other hand, you need to confirm the filling materials with the manufacturer before you create the label.

You must verify the filling materials during the pre-shipment inspection, to the extent possible.

What can happen if my products don’t carry a Law Label?

Failing to ensure that your products are correctly labeled can result in product recall and fines. It’s therefore critical to ensure that your imported products are correctly labeled – and registered – before you start selling in the United States.

Do we need Law Labels when selling on Amazon?

Amazon generally requires that products sold via its marketplace comply with the regulatory requirements in the relevant market. As such, if you sell products to one or more states with law label rules in place – then Amazon expects that you ensure compliance with these rules.

Amazon also mentions law labels indirectly on this page. The term used here is content labeling, and they also mention that a URN is required.

Can the Law Label include other labeling requirements?

No, according to a guide published by the FTC, the law label should only include information related to the law label itself. Hence, additional labeling requirements should not be covered on the same label.

Where should we go if we need help creating a Law Label?

Our recommendation is that you contact American Law Label (americanlawlabel.com) if you want help with creating the actual law label files. Many of our customers have used their services to ensure law label compliance with their products in various states.

You can also find plenty of information about Law Labels on the International Association of Bedding and Furniture Labeling Officials website (iabflo.org).

However, if you want to go into detail about the Law Label requirements for each state then you will need to access the state databases individually.