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Federal Furniture Flammability
Flammability requirements for upholstered furniture pieces are currently under development at the federal level. Expect detailed requirements as to same, including more label requirements and more record-keeping.
Both federal and state requirements apply to the marketing of children’s products and these regulatory requirements are numerous. Failure to carry the appropriate label on a child’s product may easily cause it to be pulled from sale, perhaps even recalled. We can furnish details. Contact us for a free consult. Now, more than ever, these issues matter. Don’t ignore them.

The registration and labeling of new products can be confusing. The process for offering “second‐hand” or “renovated” bedding products is even more daunting! There are federal laws and regulations in addition to many state requirements. And unlike new bedding, second‐hand bedding does not have a uniform system that is recognized by all states. Each state has its own registration and sterilization requirements and each must be addressed individually. Careful coordination of product reworking is a must. This is not for the faint of heart!The reemergence of bed bugs and the threat of Avian flu has led to greater attention on the issue of second‐hand bedding issues. Some state regulators have been known to shut down operations, such as furniture rental companies, for not fulfilling sanitization obligations required by the state. Don’t let this, or a reputation for not having properly sanitized goods, happen to you.

If your stuffed article contains any type of animal hair, feather, down or other material from animal origin and you are planning on selling your goods in the USA, you will need to obtain a sterilization permit number from the state of Pennsylvania. The rest of the states requiring this permit will only recognize a number issued from this state and you will be required to have this permit number on your label as well as your registration number. Pennsylvania will require your sterilization plant to be certified regardless of where it is located in the world.  Only when they have received this verification will they issue a permit number.

Federal and state requirements alike apply to the packaging of a product. Legal Label can help your company with those requirements, including the federal Fair Packaging and Labeling Act.

Government rules also apply to material not actually placed on a product (such as a label), but to its accompanying materials, including store posters, product hangtags and the like. We at Legal Label stand ready to assist companies with these materials.

Rules abound regarding the offering of products via the Internet. Companies should always be aware that to the extent that their products end up being shipped to any particular state, that state’s requirements need to be met. Companies need to be familiar with California Proposition 65 labeling requirements, for example.

With the great number of product safety recalls associated with goods manufactured in China (and other countries) in recent years, ″Made in USA″ claims are more important now than ever. In fact, a ″Made in USA″ statement on your product might just give your company a competitive edge. As such, you want to be able to make this claim when the facts support it.Claims of a product being made in the USA are subject to scrutiny by both federal and state agencies. Don’t ignore those rules as they may subject your company to costly fines and unwanted media coverage!Consult with us to determine if your products may legitimately contain that claim or, if not, what needs to be stated on both the product and its packaging.

Country of origin labeling requirements mandated by U.S. Customs and Border Protection are separate from those administered by the Federal Trade Commission (FTC) under the Textile and Wool Acts and Rules. For example, FTC rules do not require labeling until a textile product is in its “finished state” for sale to the consumer. Textile products imported in an intermediate stage may, in lieu of being labeled, be accompanied by an invoice with the required information.  Customs, however, may require that an unfinished product be marked with the country of origin. Manufacturers, distributors and importers must comply with both FTC and Customs requirements. The world of labeling can be confusing: check with us before you go to market!

Sometimes it happens. Despite a company’s best efforts, a label on a product is wrong. Or a product leaves the plant with a manufacturing defect. What happens then?If a safety hazard exists, a lot. We can help put your company back on the right track, advise you of the need to re‐label or put you in touch with a laboratory for help with product testing and possible modification. With The Law Offices of Joanne E. Mattiace, we can assist you in reverse distribution efforts. We will minimize your company’s discomfort.Legal Label Inc. and our affiliated firm the Law Offices of Joanne E. Mattiace have had strong experience with product “hiccups.” We can assist your company with Notices of Violations, drawing upon years of work with the various state regulators. We can help get your violation issue resolved and get a “Stop Sale” order help get your products back on sale within a minimum of time.

On April 26, 2007, the California Air Resources Board approved an airborne toxic control measure (ATCM) to reduce formaldehyde emissions from composite wood products including hardwood plywood, particleboard, medium density fiberboard, thin medium density fiberboard, and also furniture and other finished products made with composite wood products. The ATCM was approved on April 18, 2008 and the regulation has been filed with the Secretary of State to be codified into Title 17 of the California Code of Regulations, and is immediately effective. The first emissions standard was implemented on January 1, 2009.If you sell any of the above mentioned product or product made with any of the above mentioned contact us today for a FREE 15 consultation. These rules are complex and it can be a daunting task to go it alone.

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FAQ

1. What is a “law label”?

A law label is a tag attached to a product (i.e., one covered by the labeling requirements) that provides consumers certain information, e.g., product contents (both stuffing type and percentages), information as to where the product was manufactured, and specifies that “UNDER PENALTY OF LAW THIS TAG NOT TO BE REMOVED EXCEPT BY CONSUMER.”

Law labels are designed to provide consumers with information regarding the nature of the product. As such, they are designed to protect consumers from unknowingly purchasing a second‐hand product or one that contains unsafe or unsanitary fillings. These labeling requirements also serve to protect reputable manufacturers against those companies which attempt to sell non‐compliant product.

Law labels need to be a minimum of two by three inches and there are requirements as to specific text and type size as well. Some states require advance review of a given label.

If a law label is required, it needs to be “securely” attached to the product. Flammability, Textile, and Care Labels need to be ″permanently″ aƩached, in other words, they cannot be easily removed.

Items such as bed pillows, decorated pillows, bulk stuffing materials, mattresses, futons, upholstered furniture pieces, and mattress pads typically need law labels, but state laws do vary on this point.

A law label may not be combined with another label. Most states, however, will accept a bold black line between a Law and Flammability Label, enabling both labels to be one piece, yet still two separate labels.

No, but at least thirty (30) states do have such labeling requirements (Product coverage varies from state to state). For this reason, if a covered product is offered for sale just about anywhere in the U.S. or Canada, it should probably bear a law label. Doing so preserves some flexibility to the company offering subject product.

Only one label (with one registration number) is necessary, though that registration number needs to be recognized by all jurisdictions with labeling requirements.

The Uniform Registry Number (URN), assigned by one state identifies the facility in which a given product is manufactured. The prefix of that registration number indicates which state issued the number. The suffix of the registration number indicates the location (either state or foreign country) in which the facility that actually manufactured the product is located. Registration numbers can be sought from any of the states with registration requirements. That number can then be recognized by other jurisdictions.

A registration number is a registered identification number issued by the Federal Trade Commission. This number is used to identify US businesses and is defined under the Textile Fiber Products Identification Act. This number should not be confused with a Uniform Registry Number (URN) and cannot be used as such.

While the product may seem “identical,” the law label on product manufactured at one site would bear a different registration number than that on the label on product produced at another site. Each manufacturing facility requires its own URN number. This enables a state inspector to trace back the origin of a given product in case of a problem or a possible need to recall a product.

Fees are contingent upon whether or not you are registering as a manufacturer, importer, wholesaler, retailer, or supply dealer. These fees range from $5 per state to $720 per state with a total cost for all required states of approximately $3500 (this includes Ohio’s required laboratory testing fee). State certificate validity also varies from annual, every two years, and three year registration periods. In addition, some states charge per item fees according to the amount of items sold annually in the specific state. These fees vary as well. for more info, visit states that require registration.

Maintenance and management is critical, and if a number lapses, there can be real repercussions, such as going through the entire registration process again, fines could be levied, and sale of product may also be suspended.

The original certificate should be kept, and posted, at the production facility.

In cases of non‐compliance, product can be pulled from retail shelves and a company can be levied a fine.

Canada has its own law labeling requirements. U.S. and Canadian labels may both be attached to a product.

We accept Wire transfers and U.S. bank checks. If you have to pay by credit card please discuss the possibility with us.

Our follow up and our close association with The Law Offices of Joanne E. Mattiace, (a highly respected law firm that specializes in assisting companies with product‐related safety responsibilities) makes us unique and makes Legal Label, Inc. your best choice!

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