Law labels inform consumers about the filling materials inside beddings, plush toys, and other stuffed products. Although law labels are not part of federal regulations, many states in the US have such requirements – the principle of which is generally similar across the covered states.
US law labeling requirements cover products such as upholstered furniture, bedding products, sleeping bags, or cushions.
Although the labeling rules and contents are similar, the requirements pertaining to products and their registration may differ among states. In this guide, we list nine product categories covered by law labeling requirements and the corresponding labeling contents and other rules.
General requirements
In general, a law label should include information such as the following:
- A “Do Not Remove” statement
- Filling materials (weight in %)
- Uniform Registry Number (URN)
- Company name
Product List Creation Methodology
We list products that are covered by the law labels in the states of California and Pennsylvania. Note that, although the law labels of all states are similar, the list of covered products might vary. Hence, this is not a list of every single product covered by US law labeling requirements.
Content Overview
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Upholstered Furniture
Although many states have regulations for upholstered furniture, in this section we focus on the law label requirements in California.
The Bureau of Household Goods and Services (BHGS) of California defines “upholstered furniture” as any furniture made or sold with loose or attached cushions. Upholstered furniture can also be stuffed with filling material, which can be concealed by fabric that may be a part of the furniture itself.
The definition does not include furniture that is used specifically for physical fitness and exercise.
Label Information
In California, importers and manufacturers of upholstered furniture need to securely attach Type No. 1 or Type No. 2 labels onto their products.
Type No. 1 Label
Type No. 1 labels, which apply to upholstered furniture without loose cushions, require information such as the following:
a. “Do Not Remove” statement
b. Statement “ALL NEW MATERIAL consisting of…”
c. Description of filling material
d. Registry number
e. Certification statement
f. Name and address of the vendor or manufacturer (optional)
Type No. 2 Label
Type No. 2 labels, which apply to furniture with loose cushions, require information such as the following:
a. “Do Not Remove” statement
b. Statement “ALL NEW MATERIAL consisting of…”
c. Description of filling material (including filling material for back and seat cushions)
d. Registry number
e. Certification statement
f. Name and address of the vendor or manufacturer (optional)
Examples
These labels cover upholstered furniture such as:
- Upholstered furniture without loose cushions
- Furniture with loose cushions
- Quilted bedspreads
- Headboards
- Chair with cushions
Learn More
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Bedding Products
The BHGS of California defines “bedding” as a product that can be stuffed or filled in whole or in part with any concealed substance or material, and which can be used by people to sleep or recline upon.
Label Information
In California, importers and manufacturers should securely attach Type No. 6 labels to their bedding products. The label includes the following:
a. “Do Not Remove” statement
b. Statement “ALL NEW MATERIAL consisting of…”
c. Description of filling material
d. Finished size (in width and length) of the product, expressed in inches
e. Registry number
f. Certification statement
g. Name and address of the vendor or manufacturer (optional)
Examples
There are many types of bedding products, including the following:
- Bed pillows
- Comforters
- Mattress pads
- Quilt
Learn More
a. Bedding and Pillow Regulations in the United States: An Overview
b. Mattress Regulations in the United States: An Overview
Sleeping Bags
California’s and Pennsylvania’s law labels require sleeping bags to have a law label attached to them. In this section, we focus on the labeling requirements for sleeping bags in California.
The BHGS categorizes sleeping bags as a product that can be filled or stuffed with any concealed material or substance, and that can be used by any person for reclining or sleeping purposes.
Label Information
The BHGS requires importers and manufacturers to securely attach Type No. 7 labels onto sleeping bags. These labels cover sleeping bags, and require information such as the following:
a. “Do Not Remove” statement
b. Statement “ALL NEW MATERIAL consisting of…”
c. Description of filling material
d. Finished size (in width and length) of the product, expressed in inches
e. Net weight of the filling material in the sleeping bag expressed in pounds and ounces
f. Registry number
g. Certification statement
h. Name and address of the vendor or manufacturer (optional)
Filling Materials
The BGHS of California generally defines “filling material” as the bulk or packaged stuffing that can be designed to be used for products like upholstered furniture and articles of bedding.
Label Information
Labels should be securely attached to the bulk or packaged filling materials at the factory. The label should be positioned in such a manner that allows convenient examination. Importers and manufacturers are prohibited from, among other things, removing or altering the label on filling materials, except by the purchaser for their own use.
The description of the filling material on the label should not contain misleading information. If the filling material is made of liquid, it should be clearly labeled in an approved manner.
The law labels of California specify four types of labels with regards to filling materials:
- Type No. 4
- Type No. 5
- Type No. 8
- Type No. 9
Type No. 4 Label
These labels cover bulk filling materials such as batting and pads and require information such as:
a. “Do Not Remove” statement
b. Statement “ALL NEW MATERIAL”
c. Description of filling material
d. Net weight of the filling material, expressed in pounds and ounces
e. Certification statement
f. Registry number
g. Name and address of the vendor or manufacturer (optional)
Type No. 5 Label
These types of labels cover packaged filling materials ready for use by the ultimate customer. Type No, 5 labels require information such as the following:
a. “Do Not Remove” statement
b. Statement “ALL NEW MATERIAL”
c. Description of filling material
d. Registry number
e. Certification statement
f. Name and address of the vendor or manufacturer (optional)
Type No. 8 Label
Type No. 8 labels cover bulk material (e.g. batting) and any filling material in loose or prefabricated form used in articles of upholstered furniture. Importers and manufacturers are required to provide on these labels information such as:
a. “Do Not Remove” statement
b. Statement “ALL NEW MATERIAL”
c. Description of filling material
d. Net weight of the filling material, expressed in pounds and ounces
e. Certification statement with the added sentence “This product meets the requirements of Bureau of Household Goods and Services Technical Bulletin Number 117-2013.”
f. Registry number
g. Name and address of the vendor or manufacturer (optional)
Type No. 9 Label
These labels, which must be in red color, cover bedding articles that wholly or partially contain any secondhand (used) filling materials. The law labels require importers and manufacturers to provide information such as:
a. “Do Not Remove” statement
b. Statement “THIS PRODUCT CONTAINS SECONDHAND (USED) FILLING MATERIALS”
c. Description of any newly added filling material
d. Finished size (in width and length) of the product, expressed in inches
e. Net weight of the filling material expressed in pounds
f. Certification statement
g. Registry number
h. Name and address of the vendor or manufacturer (optional)
Examples
Examples of products used as filling material include:
- Cotton
- Wool
- Kapok
- Feathers
- Down
- Hair
- Liquid
Padded Baby Carriers
Pennsylvania’s Department of Labor and Industry (DLI) website lists padded baby carriers as a product that is regulated by the Bedding and Upholstery Law and Regulations.
Label Information
According to Subchapter A of the Bedding and Upholstery Regulations, importers and manufacturers in Pennsylvania are required to securely attach “Number 1” or “Number 2” white tags onto products such as padded baby carriers, according to the material:
a. “Number 1” tags require manufacturers to state on the tag that the article includes materials such as those derived from animals or fowl, which need to be sterilized.
b. “Number 2” tags require manufacturers to state on the tag that the article includes materials such as synthetic rubber fibers and vegetable fibers, which do not need to be sterilized.
Label content
Importers and manufacturers are required to include information such as the following information on both “Number 1” and “Number 2” tags:
a. “Do Not Remove” statement
b. “ALL NEW FILLING MATERIAL CONSISTING OF” statement and a description of the material.
c. Registration number
d. The statement “Certification is made by the manufacturer that the materials in this article are described in accordance with law.”
Additionally “Number 1” white tags require:
a. The inclusion of the phrase “CONTENTS STERILIZED”
b. The inclusion of a sterilization permit number, abbreviated on the tag as “PER NO.”
Other labeling requirements
The regulations also establish specifications for tags, such as the following:
a. Manufacturers should use good grade cloth, not paper, for tags so that they don’t flake when the tag gets worn down
b. When vinyl-covered articles include the usage of a heat-sealing process in its manufacturing procedure, vinyl tags may be approved
c. Tags should not have an area of less than 6 inches
d. The official tags should only include the statements that Subchapter A requires. Any other words or advertisements should be placed on another tag and attached to the article in such a way that it does not contradict or interfere with the statements on the official tags
e. The tag should bear the kind of filling material used in the article, in bold typeface that is at least 1/8 inch tall
f. Labels on articles with smooth undersides (e.g., slip seat chairs and padded stools) may be cardboard printed on a white background
Learn More
a. Baby Carrier Standards and Regulations in the United States: An Overview
Bumper Pads
Subchapter A of Pennsylvania’s Bedding and Upholstery Regulations includes crib (bumper) pads as one of the definitions of mattresses. As such, importers and manufacturers are required to provide law labels on crib bumper pads in accordance with the Subchapter.
Label Information
Importers and manufacturers are required to securely attach “Number 1” or “Number 2” white tags onto bumper pads, according to the material. We listed the required information on the above section (padded baby carriers).
Also, according to the general provisions of Subchapter A of the Bedding and Upholstery Regulations, when fibers obtained from wood pulp are compressed into pads, the label designation should be “cellulose fiber pad”.
Baby Bouncers
Pennsylvania’s DLI states that baby bouncers are regulated by the Bedding and Upholstery Law and Regulations.
Label Information
Similar to bumper pads and other products, importers and manufacturers need to provide relevant information on “Number 1” or “Number 2” white tags, according to the material, and securely attach them onto baby bouncers.
Travel Neck Pillows
Pennsylvania’s DLI’s website specifically lists “travel neck pillows” and “bed pillows” as products regulated by the Bedding and Upholstery Law and Regulations.
Label Information
According to our understanding, travel neck pillows are considered to be “pillows” by the regulations. As such, they should be tagged with a “Number 1” or “Number 2” white tags, according to filling the materials.
Stuffed Toys
In this section, we explain the labeling information requirements for stuffed toys established by Pennsylvania’s Stuffed Toy Regulations.
The regulations list several examples of stuffed materials, including:
- Cotton
- Feathers
- Kapok
Label Information
Subchapter H of the Stuffed Toy Regulations requires importers and manufacturers to “securely affix” a label or a tag to each stuffed toy manufactured for sale. Although importers and manufacturers can decide on the design, color, form, and size of the label, the information on it should be clearly readable.
According to the Subchapter, labels on stuffed toys should carry information such as the following:
a. A statement that the stuffed toy’s manufacturing process used all new material or all new (type) material
b. The abbreviations REG. NO. PA., followed by the importer’s or manufacturer’s registration number
Learn More
a. Toy Safety Standards in the United States: A Complete Guide
