U.S. Furniture Export URN Law Label Registration

U.S. Law Label and Uniform Registry Number (URN)

What is a Law Label?

A Law Label is a tag affixed to products such as furniture, bedding, and upholstered items, providing consumers with specific product information. Typically, this label includes material content (type and percentage of filling), country of origin, and a mandatory legal statement: "UNDER PENALTY OF LAW THIS TAG NOT TO BE REMOVED EXCEPT BY CONSUMER."

What is the purpose of the Law Label?

The purpose of a Law Label is to inform consumers about the internal, non-visible filling materials used in bedding and upholstered products. This requirement helps prevent the sale of unsafe or unhygienic used goods and protects reputable manufacturers from non-compliant competitors.

What is a Uniform Registry Number (URN), and how do I obtain one?

A URN is issued by a U.S. state after successful registration of a manufacturing facility. It must be printed on the Law Label. The URN consists of a prefix identifying the issuing state and a suffix denoting the actual manufacturing location.

Are there size and design requirements for the label?

Yes. Law Labels must be at least 2 × 3 inches. Font size and text layout must comply with specific requirements. Some states may even require label pre-approval.

How should the label be affixed?

Law Labels must be securely and permanently affixed to the product in a way that they cannot be easily removed.

Which products require a Law Label?

Products such as pillows, decorative pillows, bulk filling materials, mattresses, futons, upholstered furniture, and similar items typically require a Law Label. State requirements may vary.

Compliance in the U.S. market for bedding, upholstered furniture, and other filled products is governed by Law Labels and URNs. This document provides a comprehensive guide for manufacturers and importers to understand and comply with these regulations.

What is a Law Label?

The Law Label is a mandatory transparency measure designed to inform consumers about the types and percentages of stuffing/filling materials in products like mattresses and upholstered items. The label is legally required to be affixed and includes critical statements like:

"UNDER PENALTY OF LAW THIS TAG NOT TO BE REMOVED EXCEPT BY CONSUMER."

Products Covered by Law Labels

Typical items include: diaper changing pads, pet beds, bean bags, pillows, loungers, boat cushions, padding, mattress toppers, child safety seats, comforters, padded chairs, cribs, bolster pillows, padded bed bases, decorative pillows, dining chairs, plush toys, sports equipment padding, foundation fill, sofas, futons, mattress pads, padded straps, sofa beds, mattresses, ottomans, waterbed liners, padded toilet seats, quilts, sleeping bags, sofas, bicycle seats, etc.

Note: This list is not exhaustive. Always verify whether your product requires a Law Label.

Required Label Information

1. Manufacturer Info: Name and address for traceability and consumer inquiries.

2. Material Composition: Clear listing of filling materials, especially for items in contact with the skin.

3. Care Instructions: Cleaning and maintenance guidance.

4. Standards Compliance: Whether the product meets national/industry standards.

Definition & Construction

Law Labels are typically made from durable non-woven materials (e.g., Tyvek), and include required product content and manufacturer information, along with the legal notice about tag removal.

States Requiring Law Labels

32 U.S. states mandate Law Labels for bedding and upholstered furniture. 14 of these states also require URN registration:

- California

- Connecticut

- Delaware

- Detroit (MI)

- Massachusetts

- New York

- North Carolina

- Ohio

- Oklahoma

- Pennsylvania

- Rhode Island

- Utah

- Virginia

- West Virginia

Meaning of the URN Code

Example: OH 12345 (CN) 

"OH" = Ohio (state of issuance) 

"12345" = Manufacturer ID 

"CN" = China (manufacturing location)

URN vs. RN

URN (Uniform Registry Number) is state-issued for bedding and upholstered items. 

RN (Registered Number) is issued by the Federal Trade Commission for textile products under the Textile Fiber Products Identification Act.

Who Must Register for a URN?

Manufacturers and sometimes importers must register with each state where products are sold. Six states (CA, CT, Detroit, OH, UT, VA) require both manufacturer and importer registration. The other eight require only manufacturer registration.

Definitions:

- Manufacturer: The company with the final sewing/sealing facility.

- Importer: Any company importing and selling products in the U.S.

Significance of Registration

Non-compliance can result in product removal from stores and fines of up to $1,000 per violation. For example, selling a product in Ohio without Ohio registration is illegal and may lead to permanent sales bans.

Import Sales Scenario

In the six stricter states, both foreign manufacturers and U.S. importers must register. In the remaining eight states, only the manufacturer needs to register.

State-Specific Testing Requirements

- Ohio: Requires testing of all filling materials to match label content.

- California: Requires flammability testing for all upholstered furniture per TB117-2013.

Registration Timeline

- URN: 1–2 business days

- California: 6–8 weeks

- Other states: 2–4 weeks

Renewal Deadlines

Registration can be initiated anytime. However, renewals must be submitted no earlier than 60 days before expiration.

Sterilization Permit for Animal Hair

Some states require a Sterilization Permit on bedding containing animal hair (feathers, wool, down) or for secondhand bedding products. Without it, sale is prohibited.

Testing Services for Law Label Compliance

- CA TB117-2013 (Smoldering Test for Upholstered Furniture)

- 16 CFR 1632 (Cigarette Ignition Flammability Standard for Mattresses)

- 16 CFR 1633 (Open Flame Flammability for Mattress Sets)

- CA Prop 65 (Flame Retardant Content)

Multiple Facilities

Each factory needs its own URN, even if the products are identical. This ensures traceability and proper recall procedures if necessary.

Consequences of Lapsed Registration

Failure to maintain a valid URN may result in fines, forced re-registration, or halted product sales.

Penalties for Non-Compliance

Unregistered or improperly labeled products may be removed from shelves and incur legal penalties.

Understanding and complying with Law Label and URN regulations is vital for U.S. market success.

Canadian Provinces with Similar Requirements

Quebec, Ontario, and Manitoba have comparable Law Label regulations for bedding and upholstered furniture.

Note: In blue-highlighted states, both manufacturers and importers must register.

URN: A Closer Look

URN = REG.NO. 

A URN is a mandatory identifier for manufacturers producing certain products sold in specific U.S. states. Each URN is unique to a physical manufacturing site and is printed on the Law Label for traceability.

Structure of a URN:

1. Prefix – Issuing state

2. Manufacturer number

3. Suffix – Country of origin

Example: CA-12345(CN)

Validity of URN

URNs are not permanent. They must be renewed periodically with timely fee submissions.

Who Must Register?

Manufacturers and/or importers selling in states requiring URNs must register to ensure compliance. Even unintentional sales into a jurisdiction may hold importers/retailers liable.

Unified Registration System

A URN from one state can be used to register with other states. Only one URN is needed across all compliant jurisdictions.

Label Integration

Law Labels must be standalone. While some states allow flammability and Law Labels on the same tag, they must be clearly divided (e.g., by a black line) to remain legally distinct.