US law labels are mandatory for stuffed products in most US states. Such products can include beddings, stuffed toys, bean bags, and other stuffed products. The purpose of a law label is to inform the consumer of the filling material.
However, what makes this requirement somewhat complex is that law labels are regulated on a state level. Hence, the product scope, labeling, and registration requirements differ between states.
Methodology: This guide is primarily based on law labeling requirements in California, under Home Furnishings and Thermal Insulation Act Rules and Regulations.
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The US Law Label dates back to the early 1900s and requires that the filling materials of certain products are specified. In other words, the consumer should know what’s inside a product
This includes filling materials in pillows, mattresses, sleeping bags, and other textile products. Here’s an example: Polyurethane Foam 90%, Blended Cotton Felt 10%.
Example (California)
Yes, if you sell in one or more US states that require law labels for certain products.
Here are some states in which the US Law Label is required:
American Law Label Inc mentions that law labels are required in more than 31 states.
Generally speaking, products with filling materials require a law label – but the exact product scope differs depending on the state.
Here are examples of products that require law labels in California:
The exact contents of the law label depend on the state. This is an example listed as Type No. 1 in California’s HFTI Laws and Regulations:
Businesses often sell in more than one state, which can make it difficult to keep track of differing law label content and format requirements. One solution to this problem is to create a Uniform Law Label – which covers requirements in all affected states.
The International Association of Bedding and Furniture Labeling Officials (IABFLO) provides guidance and examples for several types of Uniform Law Labels:
In New York, California, Texas, and other states, manufacturers register and include the registration number on the Law Label. However, the registration number is only obtained from one state, and can then be used for registration in other states.
As such, you will not need a unique registration number for each state you sell in.
Importers can sometimes use the manufacturer’s URN. That said, don’t expect the average supplier on Alibaba.com to have a URN. Most non-US suppliers are not even aware of URNs or how to register. Hence, it is likely that you as the importer must take care of law label creation, and registration.
In California, the law label should be permanently affixed to the product in an area where it is easy to find. However, they do not provide any specific examples beyond that.
Keep in mind that the law label should not be placed on a sticker or hang tag that is not permanently affixed to the product. Likewise, it is not sufficient to affix the law label to the product packaging, or user instructions.
Yes, law labels are also required for products that are imported from other countries. For example, if you manufacture sleeping bags in China for sales in California, then these must come with a law label.
In practice, this means that you must provide a ready-made label file, complete with the registration number and other information.
Label Information
In addition, you must also provide the supplier with the following:
Foreign manufacturers
Do not assume that manufacturers outside the United States are even aware of the Law Label. It’s up to you as the importer to provide the label and clear instructions.
Further, you must also verify that the product is correctly labeled during the pre-shipment inspection.
Filling materials
The label must include an accurate description of the filling materials. If you’re importing custom-designed products, you should always include this in the Bill of Materials. If you’re buying a private label product, on the other hand, you need to confirm the filling materials with the manufacturer before you create the label.
You must verify the filling materials during the pre-shipment inspection, to the extent possible.
Failing to ensure that your products are correctly labeled can result in product recall and fines. It’s therefore critical to ensure that your imported products are correctly labeled – and registered – before you start selling in the United States.
Amazon generally requires that products sold via its marketplace comply with the regulatory requirements in the relevant market. As such, if you sell products to one or more states with law label rules in place – then Amazon expects that you ensure compliance with these rules.
Amazon also mentions law labels indirectly on this page. The term used here is content labeling, and they also mention that a URN is required.
No, according to a guide published by the FTC, the law label should only include information related to the law label itself. Hence, additional labeling requirements should not be covered on the same label.
Our recommendation is that you contact American Law Label (americanlawlabel.com) if you want help with creating the actual law label files. Many of our customers have used their services to ensure law label compliance with their products in various states.
You can also find plenty of information about Law Labels on the International Association of Bedding and Furniture Labeling Officials website (iabflo.org).
However, if you want to go into detail about the Law Label requirements for each state then you will need to access the state databases individually.
Disclaimer: The Site cannot and does not contain legal advice. The legal information is provided for general informational and educational purposes only and is not a substitute for professional advice. Accordingly, before taking any actions based upon such information, we encourage you to consult with the appropriate professionals. We do not provide any kind of legal advice. THE USE OR RELIANCE OF ANY INFORMATION CONTAINED ON THE SITE IS SOLELY AT YOUR OWN RISK.
Sources: Our articles are written in part based on publicly available information, and our own practical experience relating to product compliance. These are some of the primary sources we use:
Fredrik Gronkvist is a co-founder of Compliancegate.com and is based in Hong Kong. He has a background in manufacturing and quality assurance and has contributed to Bloomberg, BBC, South China Morning Post, and the Swedish National Electrical Safety Board. See Full Bio.
Prerna Agrawal December 21, 2022 at 4:31 pm What is the meaning of all new material consisting of :
My product is made of Recycled poly fiber.
what should i write
Veera Tumma January 6, 2022 at 9:43 am HI Fedrik, Polyester fibers produced from recycled PET bottles(extruded into fibers) can be named as “All New material ” in law label claim? Please advsie.
Fredrik Gronkvist January 7, 2022 at 11:30 am Hi Veera, We do not offer consulting services in the comment section
