Are you importing or manufacturing furniture products in the United Kingdom? Depending on the furniture, certain regulations may apply to your product and require you to have your product tested and labelled in a particular manner.
In this article, we cover relevant safety regulations and standards affecting various furniture products placed in the UK, such as the Furniture and Furnishings (Fire Safety) Regulations or the Timber and Timber Products Placing on the Market Regulations. This article does not apply to Northern Ireland as they follow EU rules.
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General Product Safety Regulations (GPSR)
The General Product Safety Regulations 2005 (GPSR) ensures the safety of consumer products, including furniture products, by imposing a general duty to supply safe products. The regulation includes traceability and monitoring requirements.
Thus, products should be assessed for safety. To fulfil the duty, producers should aim for a “presumption of conformity” by ensuring that their products meet applicable standards (this includes complying with national voluntary standards).
The GPSR applies to most consumer products unless a specific safety regulation covering the particular product is identified. Thus, the GPSR can be thought of as the default safety regulation.
Here are some products that may be affected by the GPSR:
- Furniture and soft furnishings
- Children’s products like cots and cribs
- Candles and other ornaments
Compliance with a referenced standard satisfies the safety requirements of the GPSR and affords the producer with a “presumption of conformity”. The following are referenced standards that relate to furniture products:
a. BS EN 581-1 – Outdoor furniture – Seating and tables for camping, domestic and contract use – Part 1: General safety requirements
b. BS EN 1129-1 – Furniture – Foldaway beds – Safety requirements and testing – Part 1: Safety requirements
c. BS EN 1129-2 – Furniture – Foldaway beds – Safety requirements and testing – Part 2: Test methods
d. BS EN 1130-1 – Furniture – Cribs and cradles for domestic use – Part 1: Safety requirements
e. BS EN 1130-2 – Furniture – Cribs and cradles for domestic use – Part 2: Test methods
f. BS EN 16890 – Children’s furniture – Mattresses for cots and cribs – Safety requirements and test methods
Importers and manufacturers should:
a. Provide relevant product safety information
b. Provide for traceability (including adding a traceability label to the product and packaging)
c. Ensure that the product is safe
d. Adopt a risk assessment system
e. Notify distributors of identified or potential risks. Where actual risks are identified, they should report to enforcement authorities and take risk preventive measures
Furniture and Furnishings (Fire Safety) Regulations
The Furniture and Furnishings (Fire Safety) Regulations 1988 (FFR) ensures that upholstered furniture and composites used for furniture products placed in the UK meet specific fire resistance levels and are appropriately labelled.
The regulation covers most furniture products that are ordinarily used for private use and collections of components designed to be assembled into such furniture products, including:
- Beds and divans (including the bases and headboards of both)
- Children’s furniture
- Cots (including carry-cots, playpens, prams and pushchairs, and any other similar article designed to contain a baby or small child)
- Mattresses (of any size)
Additionally, it covers most filling materials or stuffing found in upholstered parts of furniture or for filling products like cushions, mattresses, and pillows.
However, the regulation does not see bedding or floor coverings (including carpets and mats) as “furniture”.
The following are some standards that are referenced in the regulation:
a. BS 3379 – Combustion modified flexible polyurethane cellular materials for loadbearing applications – Specification
b. BS 5852-1 – Fire Tests for Furniture Part 1. Methods of Test for the Ignitability by Smokers’ Materials of Upholstered Composites for Seating
c. BS 5852-2 – Methods of test for the ignitability of upholstered composites for seating by flaming sources
d. BS 6807 – Method of test for assessment of ignitability of mattresses, upholstered bed bases with flaming types of primary and secondary sources of ignition
The FFR imposes labelling requirements like display labelling and placing permanent fire safety labels. Display labelling indicates the ignition resistance of the furniture item and is required for most furniture products.
A collection of furniture sold together should carry the appropriate display label for each item. It should be visible and its contents should be easy to read from both sides.
Permanent labelling is required for most furniture products and their fillings to show that they are compliant with the FFR. Permanent labelling requirements do not apply to mattresses, divans, and bed bases and BS 7177 (“Specification for resistance to ignition of mattresses, mattress pads, divans and bed bases”) provides for labelling specifications for such products.
Permanent labels can be presented in two forms depending on how much information is disclosed about the furniture product. Additionally, the label’s design is left to the importer or manufacturer. However, its content must either have the details specified in Part II or III of schedule 7 of the FFR for the long and short labels respectively.
Here is what the label should generally contain:
a. The statement “CARELESSNESS CAUSES FIRE” (Same with Part III label)
b. The name and postal code of the importer’s or manufacturer’s principal place of business address
c. Batch or identification number of the product
d. Imported date of the finished product into the UK or manufactured date of the product
e. Description of filling materials in the product
f. Description of covering materials in the product
g. Information regarding whether or not the article includes an interliner which has passed the test in Schedule 3 of the FFR (Same with Part III label)
h. Summary of measures taken to ensure that the product complies with the requirements of the FFR (only for Part III)
The FFR requires testing which must be done otherwise it may affect your furniture product. For instance, upholstery that fails the cigarette test can not be added in furniture products that fall under the FFR. The same applies to most filling materials and loose fillings that fail the relevant ignitability test.
The testing requirements are based on the standards referenced in the regulation. Note that the FFR refers to specific versions of the standards and may provide specific instructions regarding their application.
The following tests are some of the FFR required tests and should be observed when applicable:
a. The cigarette test – this test is based on BS 5852: Part 2. The referenced standard can be found in Schedule 4 of the FFR, and applies to upholstery found in most furniture
b. The match test – this test makes use of both BS 5852: Part 1 and BS 5852: Part 2, and applies to most furniture supplied with a permanent cover and other cover or fabric replacements
c. The ignitability test – the FFR requires that filling materials found in most furniture be tested against the “relevant ignitability test”. The exact test would depend filling material intended for use in the furniture product. Specifications can be found in schedule 1 of the FFR
d. Ignition resistance test – this test applies to interlinears and its specifications can be found in schedule 3 fo the FFR. It references BS 3379, BS 5852: Part 1 and BS 5852: Part 2
Importers and manufacturers should keep and make available, when necessary, evidence of compliance with the FFR for the applicable products. Depending on the product, the relevant enforcement authority may request the following Information:
a. Contact details of the manufacturer or importer who at first instance supplied the article in the UK
b. Manufacturing date of said article or date of importation of the finished product into the UK
c. Descriptions of filling material included in said article
d. Descriptions of covering materials included in said article
The information should be kept and made readily available for a period of five years from the date in which said article is supplied to the retailer.
UK Furniture Fire Safety Standards
The following are fire safety standards associated with the production of most furniture products. As mentioned in a previous section of this article, the GPSR imposes a general duty of safety to importers and manufacturers. Thus, in addition to standards provided by the FFR, other standards relating to the fire safety characteristics of some furniture products should be observed.
Below we list some fire safety standards that may be observed, dependent on the characteristics of your furniture product.
BS 5852 – Fire test of upholstered seating
BS 5852 is based on BS 5852: Part 1 and BS 5852: Part 2, both of which have been withdrawn by BSI and yet are still referenced in the FFR. It provides a test method for assessing the ignitability of material combinations like covers and fillings employed in upholstered seating by subjecting it to a smouldering cigarette and a match flame equivalent.
BS 6807 – Fire test for mattresses, upholstered divans and upholstered bed bases
BS 6807:2006 provides test methods for assessing the ignitability of mattresses, upholstered divans and upholstered bed bases by subjecting such products to differing ignition sources. It should be noted that the FFR refers to the BS 6807:1986 and provides specifications for the ignitability test as it relates to composite fillings of mattresses and bed-bases.
BS 5867-2 – Flammability test for fabrics for curtains and drapes
This standard provides flammability requirements for fabrics and fabric assemblies used in the production of non-domestic curtains and drapes. Additionally, it makes provisions for finished products that include combinations of curtains.
Children’s Furniture Safety Standards
There are specific safety standards that apply to children’s furniture products. Also, the GPSR requires consumer products to be safe with consideration of the risks posed to the end user.
Thus, importers and manufacturers would have to show that reasonable steps were taken to ensure that the product was safe, not only for its intended use but also for the foreseeable usage of the product itself.
Below we list some standards that are applicable to children furniture’s products.
BS EN 747-1 – Furniture. Bunk beds and high beds
This standard covers the strength, durability and general safety (inclusive of entrapment hazards) of bunk beds. This standard also applies to high sleeper beds.
BS EN 1130 – Children’s furniture. Cribs. Safety requirements and test methods
This standard applies to swinging, rocking or gliding cribs and static cribs and cradles. It includes tests for strength, durability and general safety.
BS EN 17191- Children’s Furniture. Seating for children. Safety requirements and test methods
This standard provides guidance for designing seating products for children. Testing requirements help improve the quality and safety of the product.
Timber and Timber Products Placing on the Market Regulations
The Timber and Timber Products Placing on the Market Regulations (UKTR) came into operation post-Brexit. It replaced its EU counterpart, but generally functions in a similar manner to the EU regulations.
Another related regulatory regime is the UK Forest Law Enforcement Governance and Trade Regulations (FLEGT). It should be noted that the two regulatory regimes may not apply to Northern Ireland.
The UKTR regulates the supply of timber to ensure that harvesting practices are legal, promotes sustainable harvesting practices, and supports global forest governance. In relation to importers and manufacturers, they should ensure that they are not supplying illegally harvested timber and products derived from illegal timber.
The regulations cover domestic and imported timber and most timber products like furniture, pulp and paper. Products covered by FLEGT regulations are set out in the voluntary partnership agreement with Indonesia.
Suppliers of timber are required to retain records relating to the buying and selling of timber or timber products. They should also comply with FLEGT licensing regulations. Currently, only timber imported from Indonesia must be accompanied by a FLEGT licence and must verify this with the Office for Product Safety and Standards. Once verified, the timber in question is considered legal and removes the obligation to exercise due diligence.
Due diligence systems
To comply with the regulations, importers and manufacturers should generally employ a due diligence system. Such a system should include:
a. Measures and procedures providing access to information concerning the operator’s supply of timber or timber products placed on the market
b. Procedures supporting the analysis and the risk-evaluation of illegally harvested timber or timber products derived from illegal timber being placed on the market
c. Measures and procedures to mitigate identified risks through obtaining additional information or seeking verification of the legality of the timber or timber product
The UK REACH regulations regulate the use of chemicals and heavy metals in products and promote different methods of assessment of possibly hazardous substances. It imposes legal obligations on importers, manufacturers, and distributors that should be observed.
The regulations cover most chemical substances in their standalone form, in mixtures, and in their form as a consumer product.
Here are some consumer products that would fall under the regulations:
- Furnitures with applied painting or coating
- Furnitures with plastic parts
- The hardware in furniture products like bolts and nails
Here are some examples of restricted substances that may be found in furniture products under UK REACH:
- Creosote oil (can be found in wood treatment)
- Azocolourants and azodyes (can be found in leather and textile)
- Polycyclic-aromatic hydrocarbons (PAH) (can be found in plastic parts)
- DINP, DIDP, DNOP Phthalates (can be found in plasticised material)
Third-party lab testing is often necessary when importing or manufacturing furniture in the United Kingdom. Testing is usually conducted according to one or more applicable standards.
Here are some examples of testing that apply to furniture:
3. Chemicals and heavy metals (e.g. hardware parts, plastic parts, coating and paints)