Furniture imported to or manufactured in the United States is subject to various flammability standards. In this guide, we explain what US businesses must know about 16 CFR Part 1640, California Technical Bulletin 117-2013, ASTM standards, and more.
The guide also covers flammability testing requirements, labeling, certification, and compliance risks.
Content Overview
Do you need help with product compliance? (EU & US)
- Request a free consultation call today with Ivan Malloci to learn how we can help you with:
- Product Requirements Lists
- Product Certification
- Product & Packaging Labeling
- Lab Testing
16 CFR Part 1640 – Standard for the Flammability of Upholstered Furniture
16 CFR Part 1640 – Standard for the Flammability of Upholstered Furniture is a standard administered by the Consumer Product Safety Commission (CSPC) that provides flammability testing and labeling requirements for upholstered furniture.
Product Scope
16 CFR Part 1640.3 defines “upholstered furniture” as general-use and children’s seating furniture that meets the following criteria:
a. Upholstered products used use indoors
b. Movable or stationary upholstered products
c. Items that contain upholstered seat, back, or arms
d. Includes stuffed or filled materials and articles that are sold along with the furniture
Certification Label Requirements
16 CFR Part 1640.4 requires that upholstered products covered by the standard must bear a permanent certification label containing the following statement to demonstrate compliance:
“Complies with U.S. CPSC requirements for upholstered furniture flammability.”
The certification label should have the following characteristics:
a. Be written in plain English language
b. Have a height of at least 1/8-inch
c. Have font size no smaller than other text on the label
d. Be written in black text on a white background and surrounded by a black border
Note that importers and manufacturers of upholstered furniture covered by 16 CFR Part 1640 are not required to issue a General Certificate of Conformity (GCC).
Instead, such products should comply with the Certification Label Requirements outlined in the previous section of this article, as explained in Part VII Certification of the standard:
The COVID-19 Act provides that for purposes of testing and certification, fabric, related material, or product to which the California standard applies shall not be subject to section 14(a) of the CPSA (15 U.S.C. 2063(a)) with respect to that standard. Accordingly, section 14(a) of the CPSA does not apply to this standard for the flammability of upholstered furniture. However, the COVID-19 Act requires each manufacturer of a product that is subject to the California standard to include the statement “Complies with U.S. CPSC requirements for upholstered furniture flammability” on a permanent label located on the product, which shall be considered to be a certification that the product complies with this standard.
Source: Link
Testing Methods
16 CFR Part 1640 incorporates the requirements of California Technical Bulletin (TB) 117-2013, which details testing methods (e.g. cover fabric test) and apparatus for testing the flammability of the materials in upholstered furniture.
TB 117-2013 also refers to the test procedures outlined in the standard ASTM E1353-08a – Standard Test Method for Cigarette Ignition Resistance of Components of Upholstered Furniture.
For example, ASTM E1353-08 utilizes test methods such as the following:
- Cover Fabric Test
- Interior Fabric Test
- Welt Cord Test
- Filling/Padding Component Test
- Decking Materials Test
- Barrier Materials Test
Lab Testing
Since 16 CFR Part 1640 incorporates TB 117-2013 requirements, importers and manufacturers have to ensure that their furniture products are compliant with the requirements of the standard, such as the one listed above.
Importers and manufacturers can send their products to be tested at labs that include the following:
- Intertek
- SGS
- Berkeley Analytical
ASTM Furniture Flammability Safety Standards
The ASTM, which releases standards and test methods for many products, has a specific committee for fire safety standards.
ASTM Committee E05 on Fire Standards
The ASTM Committee E05 on Fire Standards was formed in 1904. Committee E05’s primary responsibility is to develop, inspect, and revise fire standards for furniture products and building materials regularly to ensure the safety of the applicable products to humans and the environment.
The Committee established analysis and testing methods to assess the flammability and fireproofing capability of the materials and assemblies used in the products.
Currently, Committee E05 has nine technical subcommittees that develop, regulate, and maintain various flammability standards, including:
- E05.11 Fire Resistance
- E05.14 External Fire Exposures
- E05.21 Smoke and Combustion Products
- E05.22 Surface Burning
- E05.23 Combustibility
ASTM Standards
The ASTM has established a series of flammability test standards and requirements for the composites and materials used in upholstered furniture, under the circumstances of open flame, smoldering, burning, or combustion.
The following are several ASTM Standards concerning this subject:
a. E1352 – Standard Test Method for Cigarette Ignition Resistance of Mock-Up Upholstered Furniture Assemblies
b. E1353 – Standard Test Methods for Cigarette Ignition Resistance of Components of Upholstered Furniture
c. E1537 – Standard Test Method for Fire Testing of Upholstered Furniture
d. E1822 – Standard Test Method for Fire Testing of Stacked Chairs
e. E2187 – Standard Test Method for Measuring the Ignition Strength of Cigarettes
f. E2280 – Standard Guide for Fire Hazard Assessment of the Effect of Upholstered Seating Furniture Within Patient Rooms of Health Care Facilities
For instance, E1352- is designed to assess the flammability of upholstered furniture material (e.g. covers, fillings, cushioning materials) under the circumstances of exposure to smoldering cigarettes.
ASTM Flammability Safety Standards Lab Testing
In the interest of safety, it is important that furniture undergo and pass lab tests performed per relevant flammability safety standards, such as those listed above.
Here we provide a few companies that offer testing capabilities per such ASTM standards:
- Intertek
- SGS
- Eurofins
- UL Solutions
- Element
NFPA Furniture Flammability Safety Standards
The National Fire Protection Association develops different types of standards and codes, including flammability standards.
NFPA Standards
The NFPA provides a list of codes and standards relevant to fire safety, some of which apply directly to furniture flammability, for example:
a. NFPA 260 – Standard Methods of Tests and Classification System for Cigarette Ignition Resistance of Components of Upholstered Furniture
b. NFPA 261 – Standard Method of Test for Determining Resistance of Mock-Up Upholstered Furniture Material Assemblies to Ignition by Smoldering Cigarettes
c. NFPA 266 – Standard Method of Test for Fire Characteristics of Upholstered Furniture Exposed to Flaming Ignition Source
d. NFPA 272 – Standard Method of Test for Heat and Visible Smoke Release Rates for Upholstered Furniture Components or Composites and Mattresses Using an Oxygen Consumption Calorimeter
e. NFPA 277 – Standard Methods of Tests for Evaluating Fire and Ignition Resistance of Upholstered Furniture Using a Flaming Ignition Source
NFPA Flammability Standards Lab Testing
As for ASTM standards, NFPA standards can help you to assess the flammability properties of your products. For instance, while NFPA 260 includes test methods against cigarette ignition, NFPA 266 focuses on methods against flaming ignition sources.
Here are several companies that offer NFPA testing services:
- Element
- Intertek
- UL Solutions
- SGS
State Furniture Flammability Safety Regulations
Some states in the United States have established their standards regarding the flammability of furniture products. We introduce several state standards in the following sections.
California Technical Bulletin 117-2013
California Technical Bulletin (TB) 117-2013 sets labeling requirements and test methods for determining the flammability of upholstered furniture.
Labeling requirements
Upholstered furniture that comply with TB 117-2013 are required to carry a flammability label that has the following information on it:
|
NOTICE THIS ARTICLE MEETS THE FLAMMABILITY REQUIREMENTS OF CALIFORNIA BUREAU OF HOUSEHOLD GOODS AND SERVICES TECHNICAL BULLETIN 117-2013. CARE SHOULD BE EXERCISED NEAR OPEN FLAME OR WITH BURNING CIGARETTES. The upholstery materials in this product: __________ contain added flame retardant chemicals __________ contain NO added flame retardant chemicals The State of California has updated the flammability standard and determined that the fire safety requirements for this product can be met without adding flame retardant chemicals. The State has identified many flame retardant chemicals as being known to, or strongly suspected of, adversely impacting human health or development. |
Testing methods
TB 117-2013 provides different test methods, each of which applies to different materials used in upholstery:
a. Cover fabric test – used for testing outer cover fabrics
b. Barrier materials test – used for testing the materials found between the cover fabric and the resilient filling materials inside
c. Resilient filling material test – used for testing the resilient filling materials that are used inside upholstered seating furniture
d. Decking material test – used for testing the resilient materials that are used under loose cushions
California Technical Bulletin 116
California Technical Bulletin (TB) 116 is a voluntary standard that sets test procedures, and apparatus used for testing the flame retardance of movable and stationary upholstered furniture, including children’s furniture.
Labeling requirements
According to the Bureau of Household Goods and Services Label Examples document, upholstered furniture complying with both TB 116 and 117 should carry a flammability label that has the following information on it:
|
NOTICE THIS ARTICLE MEETS THE FLAMMABILITY REQUIREMENTS OF CALIFORNIA BUREAU OF HOUSEHOLD GOODS AND SERVICES TECHNICAL BULLETINS 116 AND 117-2013. CARE SHOULD BE EXERCISED NEAR OPEN FLAME OR WITH BURNING CIGARETTES. The upholstery materials in this product: __________ contain added flame retardant chemicals __________ contain NO added flame retardant chemicals The State of California has updated the flammability standard and determined that the fire safety requirements for this product can be met without adding flame retardant chemicals. The State has identified many flame retardant chemicals as being known to, or strongly suspected of, adversely impacting human health or development. |
Testing methods
TB 116 states that specimens of upholstered furniture are deemed non-compliant under the standard if they do not meet the following two conditions:
a. If there is fire and combustion occurs
b. If there is a burn mark more than two inches away from the burning end of a cigarette let on the product
California TB 116 specifies test methods to determine the flame retardance of upholstered furniture, each using three lit cigarettes that are covered with a layer of sheeting material.
Here are some of the tests>
a. Smooth surface and decking tests – The cigarettes, placed on smooth surfaces, are supposed to burn without inflaming the surface of the furniture
b. Welt test – Where three burning cigarettes are placed into a depression in the furniture to test the furniture’s flammability
c. Quilted location test – The cigarettes are placed on quilted locations on the furniture
d. Tufted location test – If the upholstered furniture has tufts, the cigarettes should be placed there
e. Crevice test – If the furniture has crevices, the cigarettes should be placed there
f. Tops of arms and backs test – If the furniture has arms and backs, then the cigarettes should be placed on the tops of those
Boston BFD IX
The Boston Fire Department (BFD) established Article IX to its Fire Prevention Code, which states that furnishings, decorations, and interior finishes should be tested concerning how resistant the test specimens are to the following:
- Ignition
- Flame spread
- Heat release potential
- Smoke-producing characteristics
A Fire Department’s Chemist should conduct the relevant tests. However, the Fire Department also accepts test reports from labs or testing companies that have an established system and procedure for testing furnishings. The Fire Department may request those labs to provide evidence that they have the required equipment and are qualified to carry out such tests.
BFD IX-1
BFD IX-1 is a test method used to classify the flammability of partition furnishing products such as curtains, drapes, cubicle curtains, fabric coverings on walls, and space dividing panels.
BFD IX-10
BFD IX-10 is a regional standard applied in the jurisdiction area of Boston, that regulates the flammability resistance performances of upholstered and reupholstered seating products.
BFD IX-10’s testing methods and requirements are largely based on ASTM E1537 and California Technical Bulletin 133, even if the latter one has been repealed in 2019.
BFD IX-10 mainly evaluates the performance of the upholstered furniture products based on the following test parameters: rate of heat release, total heat release, total mass loss, carbon monoxide, and smoke opacity.
BFD IX-11
BFD IX-11 is a full-scale fire test procedure to evaluate the flammability performance of upholstered products like box springs, and bedding intended for use in healthcare facilities, hotels, and dormitories.
Compliance Risks
Furniture covers and filling materials are not compliant with US flammability safety standards by default. There is plenty of furniture manufactured for other countries and markets, which therefore are made using materials compliant with US flammability standards in mind.
It’s therefore critical that importers buying furniture, or materials for domestic furniture manufacturing, verify compliance before shipment to the United States. This is usually done through third-party lab testing.
Further, it’s also necessary to inform your supplier of which standards the materials must be compliant with.
Great Article to read. Thanks for sharing