U.S. Law Label (URN Number) Registration Q\&A

What is a Law Label?

The Law Label originated in the early 19th century, designed to inform consumers about the "unseen" filling materials inside bedding and upholstered furniture. These are referred to as “Stuffed/Filling Materials” in English. It is a legally binding label attached to the product to describe the fabric and filling materials/percentages in mattresses, upholstered furniture, and soft-filled items such as pillows, cushions, stuffed toys, etc.

Definition of Law Label

Law labels are usually made from durable high-density non-woven fabric (such as Tyvek). They provide consumers with essential information about the product, including filling materials and their percentages, manufacturer details, and other relevant information. For bedding and furniture-related products, the label also explicitly states:

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

U.S. States Requiring Law Labels

Currently, 32 U.S. states mandate the posting of Law Labels on bedding and upholstered furniture, and 14 of those states require registration of a Uniform Registration Number (URN).

Products Requiring Law Labels in the U.S.

• Baby Changing Pads

• Pet Beds

• Bean Bags

• Bed Pillows

• Reclining Chairs

• Boat Seating

• Bumper Pads

• Sleeping Pads

• Children’s Car Seats

• Comforters

• Upholstered Chairs

• Cribs

• Cushions

• Upholstered Headboards

• Decorative Pillows

• Dining Room Chairs

• Stuffed Toys

• Exercise Equipment Cushions

• Filling Materials in Bulk Foundations

• Loveseats

• Futons

• Mattress Pads

• Padded Baby Carriers

• Upholstered Dual Purpose Furniture

• Mattresses

• Ottomans

• Waterbed Mattress Liners

• Padded Toilet Seats

• Quilts

• Sleeping Bags

• Sofas

• Bicycle Seats

Note:The above list includes commonly regulated products under Law Label requirements. If your product is not listed, it does not necessarily mean it is exempt. Please contact us for further confirmation—we can consult relevant state authorities.

What is a Uniform Registration Number (URN)?

The URN appears in a designated location on the Law Label. It is a registration number issued by one of the 14 registering states and is recognized by the others during their registration process. Each manufacturer or manufacturing facility address must apply for a separate Law Label. If a company has multiple manufacturers or facilities, each address must have a distinct URN.

Significance of the URN Code

The URN ensures that the manufacturer has a valid and legal registration record and documentation. For example, in the code (OH 12345 (CN)), "OH" indicates that Ohio issued the number, and "CN" denotes that the product was manufactured in China.

Difference Between URN and RN Codes

URN (Uniform Registration Number) and RN (Registered Number) serve different purposes. RN is issued by the Federal Trade Commission (FTC) and is used to identify businesses operating within the U.S. under the Textile Fiber Products Identification Act. URN, on the other hand, is specific to bedding and upholstered products.

Who Should Register for a URN?

Manufacturers or importers of bedding and upholstered furniture selling in the U.S. should register with the states where their products are sold. Among the 14 states, 6 states (California, Connecticut, Detroit, Ohio, Utah, and Virginia) require both foreign manufacturers and local importers to register. The remaining 8 states require only the manufacturer to register.

Definition of Manufacturer

A manufacturer is defined as the company that owns the facilities where the product is finally sewn and sealed—not the distributor, wholesaler, or importer. If the product is made by another company, then that company is considered the manufacturer.

Definition of Importer

An importer is any company that imports products from abroad (the place of manufacture) and sells them either directly or through another company in the U.S.

Significance of Registration

Manufacturers or importers must register according to the law in the states where their products are sold. Selling unregistered products is illegal in the U.S. If discovered, such products will be immediately withdrawn from stores and sales channels, and penalties of \$1,000 per violation or more may apply. For example, if a company fails to register in Ohio but sells products there, it will be fined, and the product will be permanently banned from sale in Ohio.

How to Apply If the Product is Sold Through an Importer?

In such cases, 6 out of the 14 states require both foreign manufacturers and local importers to register. The other 8 states only require the foreign manufacturer to register. Foreign manufacturers should confirm registration status with the local importer.

Testing Requirements in Ohio

To avoid health risks caused by inaccurate label information, Ohio requires all filling materials to be tested to ensure consistency with what is displayed on the label.

Testing Requirements in California

California mandates that all upholstered furniture must pass flammability tests. Products must comply with TB117-2013regulations for filling materials and fabrics. Effective January 1, 2014, TB117-2013 became the official flammability standard for upholstered furniture, and all manufacturers must comply during production.

Certificate Renewal Deadlines

The initial registration application can be submitted at any time. Once the Uniform Registration Number (URN) is issued, the certificate must be renewed according to each state's designated deadline. Renewal applications cannot be submitted earlier than 60 days before the expiration date.

Annual Renewal Deadlines:

• North Carolina (NC): February 28

• Connecticut (CT): April 30

• Oklahoma (OK): June 30

• West Virginia (WV): June 30

• Detroit (DET): June 30

• Utah (UT): December 31

States with a One-Year Validity:

l Delaware (DE)

l Massachusetts (MA)

l New York (NY)

l Ohio (OH)

l Pennsylvania (PA)

l Virginia (VA)

Other Validity Periods:

California (CA): Valid for 2 years

Rhode Island (RI): Valid for 3 years

Sterilization Permit Number Registration for Animal Hair Products

In addition to the URN, some U.S. states require that bedding products containing animal hair (down, feathers, wool) and second-hand bedding sold in the state must carry a label with a sterilization permit number issued by a designated state agency. Products without this label are not permitted for sale.

Law Label-Related Testing Services Include:

• CA TECHNICAL BULLETIN 117:Test Procedure and Apparatus for Testing the Smolder Resistance of Materials Used in Upholstered Furniture

• 16 CFR 1632:Standard for the Flammability of Mattresses and Mattress Pads (FF 4-72, Amended)

• 16 cfr 1633:Standard for the Flammability (Open Flame) of Mattress Sets

• CA Prop 65:Flame retardant content testing

China JJR Laboratoryhas many years of experience in U.S. Law Label (URN number) registration. We provide flexible and customized registration solutions based on client needs, including label inspection, design, and other one-stop services. Please contact JJR LAB service for more information.