Furniture Regulations in the United States: A Complete Guide

Furniture products manufactured, imported, and sold in the United States must comply with different safety regulations and standards. Requirements cover mechanical safety, flammability, and chemicals.

In this guide, we take a closer look at various regulatory requirements that concern a wide range of furniture.

Relevant products

• Upholstered furniture
• Wooden furniture
• Bunk beds
• Coated and painted furniture
• Clothing storage units
• Adult portable bed rails
• Children’s furniture

General-use Products

The Consumer Product Safety Commission (CPSC) describes General-use products as consumer products that are not designed for children who are 12 years old or younger.

Some general-use products must comply with mandatory safety rules that may require compliance with testing, labeling, documentation (e.g., General Certificate of Conformity (GCC)), and other requirements.

Here I list the safety rules for general-use products that I deem relevant for furniture.

Part	Scope	Key Requirements
16 CFR Part 1213 – Safety Standard for Entrapment Hazards in Bunk Beds	Bunk beds	This rule aims to reduce entrapment risks for kids. I found requirements for: Guardrails Bed end structures Test methods Marking and labeling Instructions
16 CFR Part 1261 – Safety Standard for Clothing Storage Units	Clothing storage units	This rule intends to protect young children from tip-over-related death or injury. It mandates that each clothing storage unit that is subject to ASTM F2057-23 – Standard Safety Specification for Clothing Storage Units should comply with the standard’s requirements.
16 CFR Part 1270 – Safety Standard for Adult Portable Bed Rails	Adult portable bed rails	The rule mandates compliance with the requirements of ASTM F3186-17 – Standard Specification for Adult Portable Bed Rails and Related Products. However, the rules specify several changes in the standard requirements. This includes: Physical requirements Testing requirements Warning statements and instructions
16 CFR Part 1303 – Ban of Lead-Containing Paint and Certain Consumer Products Bearing Lead-Containing Paint	Paint and similar surface-coating materials for consumer use that contain lead or lead compounds	This rule bans: a. Furniture products for consumers that contain “lead-containing paint” b. Toys and other products for children that contain “lead-containing paint” c. “Lead-containing paint”, which means paint or other similar surface coating materials containing lead or lead compounds above 0.009% by weight. It defines furniture as movable articles that are used to support people and things, or have other functions, such as bookcases, pianos, etc. It also lists exceptions.

General Certificate of Conformity (GCC)

You must draft a General Certificate of Conformity (GCC) if you import or manufacture any of the products covered by the above-mentioned rules – or any other rule that requires a GCC.

A GCC is, in practice, a self-declaration where you state that the product was tested and complies with the relevant CPSC rules and standards (e.g., ASTM standards).

eFiling

If you import products that are covered by a GCC (or by a Children’s Product Certificate, if you import children’s products), you must register and submit the necessary data via eFiling.

Before you can go ahead and submit your data on the CPSC’s website, you should:

• Identify the relevant safety rules
• Design your product so that it complies with such rules
• Test your product
• Draft a GCC

Upholstered Furniture

This section covers requirements that are specific to upholstered furniture, such as products made or sold with a cushion.

16 CFR Part 1640 – Standard for the Flammability of Upholstered Furniture

16 CFR Part 1640 establishes a standard for the flammability of upholstered furniture, which is defined as:

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(1) Means an article of seating furniture that—

(i) Is intended for indoor use;

(ii) Is movable or stationary;

(iii) Is constructed with an upholstered seat, back, or arm;

(iv) Is:

(A) Made or sold with a cushion or pillow, without regard to whether that cushion or pillow, as applicable, is attached or detached with respect to the article of furniture, or

(B) Stuffed or filled, or able to be stuffed or filled, in whole or in part, with any material, including a substance or material that is hidden or concealed by fabric or another covering, including a cushion or pillow belonging to, or forming a part of, the article of furniture; and

(v) Together with the structural units of the article of furniture, any filling material, and the container and covering with respect to those structural units and that filling material, can be used as a support for the body of an individual, or the limbs and feet of an individual, when the individual sits in an upright or reclining position;

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This includes products that are intended to be used by children.

It sets the following requirements:

a. Certification and labeling

b. Compliance with Technical Bulletin (TB) 117-2013 – Requirements, Test Procedure and Apparatus for Testing the Smolder Resistance of Materials Used in Upholstered Furniture

US Law Labels

US law labels are state regulations that set mandatory labeling requirements for stuffed products in many US states. The goal is to inform consumers of the filling material included in the product.

While the scope may vary according to the state, the following products are often subject to US Law Labels requirements:

• Upholstered furniture
• Pillows
• Bean bags
• Filling materials

You can visit the International Association of Bedding and Furniture Labeling Officials (IABFLO)’s website to learn about the requirements in the states where you want to sell.

Wooden Furniture

This section covers requirements that are specific to wooden furniture.

Title	Scope	Key Requirements
7 CFR Part 319 Subpart I – Logs, Lumber, and Other Wood Articles	This part sets requirements for wooden handicrafts and other wood products. Wooden handicrafts include: Garden and lawn/patio furniture (rustic) Other items composed of wood	This part sets requirements related to: Prohibitions Permits Treatment Labeling and marking
Lacey Act	Plants, fish, and wildlife, including wooden furniture products such as: Bent-wood kitchen furniture Wooden furniture of a kind used in offices	This part sets requirements for: Due care Declaration
40 CFR Part 770 – Formaldehyde Standards for Composite Wood Products (TSCA)	Composite wood products	This part sets requirements for: Substance restrictions Certification Testing Reporting Record-keeping Labeling

Furniture Textiles

16 CFR Part 303 – Rules and Regulations Under the Textile Fiber Products Identification Act sets labeling requirements for textile products.

Part 303.45 – Coverage and exclusions from the Act lists the following among the list of covered products:

• Furniture slip covers and other covers or coverlets for furniture
• Dresser and other furniture scarfs
• Curtains and casements
• Draperies
• Cushions
• Floor coverings
• All fibers, yarns and fabrics
• Afghans and throws

In general, 16 CFR Part 303 requires the following labelling information:

• Fiber content (e.g., 80 percent Cotton, 20 percent Nylon)
• Company name or a registered identification number
• Country of origin

It also sets documentation requirements, that is, record-keeping, invoicing, and  an optional guaranty.

CPSIA – Children’s Furniture

Furniture intended for children up to 12 years must comply with the CPSIA requirements. Here is a list of key requirements:

1. Compliance with all relevant children’s product safety rules and substance restrictions (e.g., lead, phthalates)

2. Testing from a CPSC-accepted lab

3. Children’s product certificate (CPC)

4. Tracking label

5. eFiling (for imported products)

Besides that, 16 CFR Part 1130 sets additional labeling and registration form requirements for durable infant or toddler products. This includes the following furniture products and accessories:

• Cribs
• Toddler beds
• High chairs, booster seats, and hook-on chairs
• Bath seats.
• Gates and other enclosures for confining a child
• Play yards
• Stationary activity centers
• Bassinets and cradles
• Children’s folding chairs and children’s folding stools.
• Baby changing products
• Infant bouncers
• Bed rails
• Crib mattresses
• Nursing pillows
• Infant support cushions

Other Requirements

This section lists additional requirements relevant to furniture in the United States.

Furniture flammability

Besides 16 CFR Part 1640 – Standard for the Flammability of Upholstered Furniture, which I have already covered in this guide, there are also other flammability standards that furniture must comply with.

The table below lists the standards that I could find (but more standards may exist). Some standards may be voluntary in theory, as they are not incorporated by reference in any US federal or state regulations.

However, you must still ensure that your product is safe. Thus, your products should also comply with voluntary standards, if relevant.

Title	Scope	Incorporation by reference
ASTM E1537 – Standard Test Method for Fire Testing of Upholstered Furniture	Upholstered furniture	None found
ASTM E1822 – Standard Test Method for Fire Testing of Stacked Chairs	Stacked chairs	None found
ASTM E2187 – Standard Test Method for Measuring the Ignition Strength of Cigarettes	Upholstered furniture, bedding	None found
ASTM E2280 – Standard Guide for Fire Hazard Assessment of the Effect of Upholstered Seating Furniture Within Patient Rooms of Health Care Facilities	Upholstered seating furniture in patient rooms of health care facilities	None found
ASTM E1474 – Standard Test Method for Determining the Heat Release Rate of Upholstered Furniture and Mattress Components or Composites Using a Bench Scale Oxygen Consumption Calorimeter	Upholstered furniture and mattress components	None found
NFPA 260 – Standard Methods of Tests and Classification System for Cigarette Ignition Resistance of Components of Upholstered Furniture	Upholstered furniture components	None found, but it may be used in some building codes and regulations
NFPA 261 – Standard Method of Test for Determining Resistance of Mock-Up Upholstered Furniture Material Assemblies to Ignition by Smoldering Cigarettes	Upholstered furniture mock-ups	None found, but it may be used in some building codes and regulations
California Technical Bulletin 117-2013	Materials used in upholstered furniture	Yes, 16 CFR Part 1640
California Technical Bulletin 116	Upholstered furniture	None found, but mandatory in California
Boston BFD IX	Upholstered products, textile, decorative materials, floor coverings, mattresses	None found, but mandatory in Boston

19 CFR Part 134 – Country of Origin Marking

The manufacturing country of the furniture must be indicated. For example, furniture manufactured in Vietnam may be labeled as Made in Vietnam.

That said, §134.33 J-List exceptions state that the packaging can be marked with the country of origin as long as it reaches the customer.

Examples

Made in Mexico

Made in Vietnam

Made in Italy

16 CFR Part 323 – Made in USA Labeling

Strict requirements apply to furniture marked as Made in the USA. Some of the key requirements are summarised below:

1. All significant processing that goes into the furniture must occur in the United States

2. All or virtually all materials and parts of the furniture must be made and sourced in the United States

California Proposition 65

California Proposition 65 sets substance restrictions for products sold in California, which includes furniture. Surface coatings, paints, and other treatments applied to furniture can contain phthalates, lead, and other restricted substances.

Third-party lab testing is often required to verify compliance.

That said, companies generally also have the option to affix warning labels.

FAQ

Is product testing required for furniture?

Safety and chemical testing is mandatory for children’s furniture and furniture covered by various general-use product safety rules.

Generally speaking, all consumer products must be safe, and it is in your interest as a manufacturer or importer to ensure that mechanical safety, flammability, and chemical safety is verified.

Is a GCC required for furniture?

A General Certificate of Conformity (GCC) is generally required for the following types of furniture:

• Bunk beds
• Clothing storage units
• Portable Bed Rails
• Painted or coated furniture

The latter is due to 16 CFR Part 1303, which restricts lead.

Is a CPC required for children’s furniture?

Yes, children’s furniture manufactured in or imported to the United States requires a Children’s Product Certificate (CPC).

Is eFiling required for furniture?

eFiling is required if you import either:

a. Children’s furniture that requires a CPC (which is essentially all children’s furniture)

b. Furniture that requires a GCC (see list above)

Do furniture sold in the US require country of origin marking?

Yes, but there is an exemption to the placement of the country of origin mark, which may (in some cases) be affixed to the furniture box rather than the furniture piece itself.

Does California Proposition 65 apply to furniture?

Yes, California Proposition 65 sets substance restrictions that also apply to furniture. For example, formaldehyde may be found in furniture that is made of composite wood.