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Laws and Regulations

San Francisco Ban of Flame Retardants

Posted on by EA Accounts

San Francisco’s ordinance to ban flame retardants was unanimously approved on October 17th, 2017. It was sponsored by Supervisor, Mark Farrell of District 2 on the City and County San Francisco Board of Supervisors.

 

The ban goes into effect as of January, 1st 2019. Certain companies have been given an additional six months to comply. All other companies are expected to sell any and all “juvenile product or upholstered furniture” with less than “1,000 ppm of any flame retardant chemical”. The ban does not include children’s mattresses unless they meet 16 CFR Part 1632 or 1633.

Details are not currently available of how or if this will affect the California’s flammability label.

Need help with a flammability label? Contact Us.

California Prop 65 Compliance Memo

Posted on by EA Accounts

Chemical Warning Requirements

Prop 65 Memo Available from the Law Offices of Joanne E. Mattiace

You may have heard that there are changes coming down the pike in regards to California Prop 65.  Some of you have indicated great concern about  these changes.  To assist you with  offering consumer products in California, we have prepared a short compliance document which can help you with your approach to such product offerings.  Please let us know if you would like to order a copy of that memo.

Stay Compliant

Contact The Law Offices of Joanne Mattiace for Your Copy Today

Prop 65 Memo for Clients of Legal Label and Joanne Mattiace Prop 65 Memo for Non-Clients

Clients of Joanne’s law firm also get a 30 minute follow up with Joanne.

Contact Legal Label for all your law label and state licensing needs today.

EPA Formaldehyde Law Label Change

Posted on by EA Accounts

California Formaldehyde Law Label Example

US TSCA Title VI Compliant Law Label for EPA Formaldehyde Emission Standards for Composite Wood Products. 

formaldehyde law label

Law offices of Joanne E. Mattiace

If your company offers any consumer product for sale which contains any type of manufactured wood, you are likely familiar with the need to comply with California’s wood and formaldehyde labeling and emissions standard. 

Be aware that a new federal rule, both labeling and emissions, kicks in later this year. The new federal rule is similar, though not identical, to the California requirement. There has been a great deal of confusion over this federal rule but it is now slated to be effective in December of 2017. Companies may now begin to use the labels necessary to appear on products.

Now is the time to consult with your suppliers and secure documentation as to the emissions levels associated with the use of such manufactured wood in consumer products. Therefore, go ahead and begin to implement the new federal labeling requirements, and learn the new record keeping obligations imposed upon your company. Also, consult with legal counsel and/or the team at Legal Label sooner than later. Don’t put your product offerings at risk with a possible violation.

Contact the Law Offices of Joanne E. Mattiace.

 

Pennsylvania Accepts Utah Sterilization Permit!

Posted on by EA Accounts

sterilizationUtah is the first state accepted on Pennsylvania law labels. Pennsylvania used to only accept its own sterilization permit on its law label. Pennsylvania was the most stringent state, requiring a third party inspect the sterilizing method.

Utah requires certification every three years, and a yearly renewal. As a result, it’s now the strictest state. The requirement is that all products that contain a filling of animal origin, list the sterilization permit number on the law label.

Pennsylvania requires a one-time certification, but a yearly renewal.

Suppliers of wool, down, feather, and animal hair as fillings can choose between which of the two states they wish to use for their base permit. Furthermore, they still need to be registered in all states requiring sterilizing for their goods (CT, RI, MA).

Do you need a sterilization permit for your mattress, bedding, upholstered furniture, or stuffed toy?

Contact Legal Label for all your law label and state licensing needs today.

 

Rhode Island Passes H5082

Posted on by EA Accounts

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Rhode Island Bans Flame Retardants

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flame retardants

Early in spring of 2017, Rhode Island passed bill H5082 that bans the sale of “upholstered bedding and furniture” that contains more than 100 parts per million of any organohalogen flame retardant. There was stall in passing of the bill due to the General Assembly taking an adjournment in the summer. That legislation became law on September 18th, 2017 without Governor Gina Raimando’s (D) signature.

There is effort by bedding regulation organizations to define “upholstered bedding”, which is not defined in the law, and feel it is not intended to include mattresses. The legislation was largely supported by concerns about the health of firefighters.

The law takes effect July 1, 2019.

Are you a mattress, bedding, upholstered furniture, or stuffed toy manufacturer/importer that needs to be registered? Contact Legal Label for all your law label and state licensing needs today.

Maine Bans Flame Retardants

Posted on by Jen Bragdon

Upholstered Furniture, beginning 01/01/2019.

Maine is the first state in the nation to pass a law (Bill LD182) banning all flame retardants in upholstered furniture. The new law outlaws the sale of residential upholstered furniture that contains more than 0.1% of a flame retardant chemical or more than 0.1% of a mixture that includes flame retardant chemicals.

Per the legislation: “Flame-retardant chemical” means a chemical or chemical compound for which a functional use is to resist or inhibit the spread of fire. “Flame-retardant chemical” includes, but is not limited to, halogenated, phosphorus-based, nitrogen-based and nanoscale flame retardants and any chemical or chemical compound for which “flame retardant” appears on the substance safety data sheet required under 29 Code of Federal Regulations, Section 1910.1200(g) (2015).

Stay tuned as we look into this new law for more information regarding any rules that are adopted as defined in Title 5, chapter 375, subchapter 2-A.

View Law

Sterilization

Posted on by Jen Bragdon

Filling Material of Animal Origin

If you are sterilizing feather, down, or other filling material of animal origin (such as wool) you must obtain a sterilization permit from 5 states or if you are a manufacturer or importer using a sterilization permit on your law label you may want to consider proof of compliance from the sterilizer.

Note that UT’s sterilization permit applications can now be processed as of July 3rd, 2017. 

Regulation to Reduce Formaldehyde Emissions

Posted on by Jen Bragdon

Composite Wood Products

If you are a manufacturer, an importer, a distributor or a retailer of any finished product containing manufactured wood, you should be aware that the Environmental Protection Agency’s rule regarding formaldehyde emissions is back on. While the new Administration had attempted to delay the program’s effective date, that effort was met with resistance and threats of legal challenges. While we at Legal Label will have more to say about this subject in coming weeks and months, you should be aware now that the new federal program will be imposing new emissions standards for hardwood plywood, medium-density fiberboard and particleboard as of December, 2017. Laminated wood components will not fall within the scope of the new rule for 7 years and, as of now, structural plywood is exempt as well.

Labels for finished products containing such manufactured wood will also be required as will vigorous record-keeping rules.
Notably, every company in the supply chain will bear the burden of record-keeping.
Legal label will be assist to your company with its new label obligation.
Finally, note that EPA and the State of California are working together to figure out how best to phase out the California program already in existence. As is usual in these situations, a transition period will most likely be provided, thereby easing the changes with product labels
While we have yet to see a lot of details about this new program, we do advise every affected company to now start working with its wood panel suppliers in an effort to anticipate the new requirements. Do not wait!
Stay tuned for further details.