Wooden Furniture Regulations in the United States: An Overview

Planning to import or export wooden furniture to the United States? In this guide, we cover the basics of APHIS regulations, T 117-2003, CA Prop 65, country of origin labeling and much more.

Mentioned Products

• Wooden tables
• Wooden sofas and benches
• Wooden bunk beds
• Wooden chairs
• Wooden outdoor furniture
• Upholstered wooden furniture
• Children’s wooden ffurniture

Wooden Product Regulations

The Animal and Plant Health Inspection Service (APHIS) is an agency of the United States Department of Agriculture (USDA). APHIS regulates certain types of wooden furniture including:

• Bunk beds
• Toddler beds
• Upholstered furniture

Here is an overview of APHIS compliance requirements for certain wooden furniture in the United States.

Approved Suppliers

APHIS provides a list of approved suppliers for wooden furniture or other wooden handicraft products. For example, if you are planning to import wooden furniture from China, you will find a list of approved wooden furniture manufacturers on their website.

Buying wooden furniture from Chinese manufacturers that are not in the list is not an option as they are not considered approved in the APHIS perspective.

Facility Requirements

The approved supplier list is agreed by both China and the United States governments. Those suppliers are selected by criteria such as:

• Heat treatment and/or fumigation
• Facility sanitation
• Quarantine treatment to the wooden handicraft product
• Quality management such as pest control and traceability system

Pre-Import Approvals

Let us assume that you have selected a supplier on the APHIS list, the next step is to apply for the import permit for your wooden furniture. You don’t need to go to the APHIS office in the United States for this process; instead, this can be done on their ePermits website.

Note: You will need a USDA eAuthentication account for the permit application, which can be registered on the USDA website. For the USDA account, you only need to provide some general information such as:

• Product category
• The registered number of the manufacturer
• Personal contact
• Quantity of goods

The application may take up to 30 days, then you shall receive the permit. It could take longer, depending on your product type. Meanwhile, you can always check the status of the ePermit platform.

Permit

The permit indicates all necessary information for wooden furniture, or other products when importing to the United States, such as:

• Permittee name and contact
• Permit number
• Facility number
• Expiration date
• Type of treatment (fumigation or heat treatment)

If your wooden furniture contains any natural or planted forest stands components, you will also need to self-issue the declaration form including information such as:

• Tree’s scientific name
• Country of harvest
• Value
• Description

Learn more

Find more requirements that may apply to your wooden furniture on the official USDA website.

Technical Bulletin 117-2013 (TB 117-2013)

Effective from January 1, 2015, upholstered furniture sold in California must comply with TB 117-2013. TB 117-2013 sets flammability performance requirements and test standards for filling materials, decking, and furniture cover.

Before the importation, you must ensure that your wooden furniture does not contain excessive toxic flame retardant chemicals such as PBDEs and polybrominated diphenyl ethers.

TB 117-2013 Lab Testing

It is practically impossible for importers to determine whether their product is TB117-2013 compliant without any help, as it required advanced equipment and professional knowledge. Hence, a third product lab testing is the only way to assess compliance and reduce the risk of force-call and fines.

We recommend that you should book a lab testing via reputable companies such as Intertek, Bureau Veritas, or SGS before importing wooden furniture to the United States.

California Proposition 65

California Proposition 65 (CA Prop 65) covers all consumers product sold in California including wooden furniture. CA Prop 65 regulates over 800 hazardous substances, such as heavy metal and additives.

You must attach a warning label on your product and product package if it contains an excessive amount of regulated substances.

Examples of restricted substances

• Lead
• Acetamide
• Cadmium
• Bromoform
• Mercury
• Phthalates

California Proposition 65 Lab testing

If you don’t wish to attach a warning label on your product, or you are not sure about CA Prop 65 compliance, we recommend that you should book a lab testing before importing wooden furniture to the United States.

Importers should instruct their suppliers about CA Prop 65 compliance at an early stage for compliance purposes. However, most wooden furniture manufacturers cannot provide CA Prop 65 test reports. Hence, third-party lab testing would be the only option to assess CA Prop 65 compliance.

Testing costs

CA Prop 65 starts from $200 for wooden furniture. Note that the cost might increase depends on the number of products, materials, colors, and other applicable factors.

Testing companies

Find more information about the CA Prop 65 lab testing in here.

Warning Labeling

Unlike other regulations, for instance, CPSIA for children products, third-party lab testing for CA Prop 65 is not mandatory. However, you must ensure that your wooden furniture is compliant if you don’t wish to bear a warning label on the product and its packaging.

Risks

Paints and coatings used when manufacturing wooden furniture may contain excessive amounts of heavy metals and chemicals restricted by California Proposition 65. It’s therefore important to instruct your supplier to only use ‘compliant’ paints and coatings. Our recommendation is that you instruct your supplier to only use certain brands, as this reduces the risk of compliance issues.

Country of Origin

The country of Origin label is a mandatory requirement for wooden furniture in the United States. The label must be permanently and visibly affixed on the product and its packaging.

Examples

• Made in China
• Made in Thailand
• Made in India
• Made in Indonesia
• Made in Brazil

Label file

Some importers wrongly assume that their supplier is responsible for product labeling. In fact, you must self-create the label file then submit it to your supplier. For example, you shall provide a country of origin label file in .ai or .eps formats to your supplier before the manufacturing process.

CPSC Rules

Certain non-children’s products are covered by one or more CPSC rules. Some rules apply to specific products, such as bunk beds, while other CPSC rules restrict certain substances, such as lead used in furniture paint.

General Certificate of Conformity (GCC)

A self-issued General Certificate of Conformity (GCC) is required when importing certain types of wooden furniture, such as bunk beds. The GCC can be only issued by an importer or a domestic manufacturer (in the USA), declaring that the wooden furniture is compliant with all applicable CPSC and ASTM safety standards. Note that you will also need to attach all relevant test reports for verification.

In addition, the GCC is identical to the Children’s Product Certificate (CPC). The difference is that a CPC only applies to children’s wooden furniture; while the GCC applies to non-children wooden furniture.

Content Summary

1. Product description

2. List of applicable CPSC safety rules

3. List of applicable ASTM standards

4. Your company details

5. Relevant test reports

6. Production date and place

7. Product testing date and place

8. Third-party testing company contact details

Learn more

Click here to learn how to issue the GCC when importing wooden furniture.

Children’s Wooden Furniture: CPSIA

Note that CPSIA is applicable to all children’s products sold as suitable to children of 12 years or younger. The CPSIA is therefore also applicable to wooden children’s furniture, such as bunk beds.

Here’s a summary of the CPSIA requirements:

• Lab testing required
• Tracking label required
• Children’s Product Certificate (CPC) required
• Registration card required

You can learn more about CPSIA requirements here:

• CPSIA Tracking Label Guide For Importers & Amazon Sellers
• CPSIA Children’s Product Certificate (CPC): A Practical Guide
• CPSIA and ASTM F963 Product Lab Testing: A Complete Guide

ASTM Standards

Following ASTM standards are usually not mandatory for wooden furniture when importing to the United States. However, some companies still utilize applicable ASTM standards at the product development stage for enhancing product safety.

ASTM standards provide detailed testing methods and procedures for wooden furniture, which can be used to improve product safety and quality. Note that unsafe products sold in the United States can result in a heavy fine and even force call on your product.

Examples of wooden furniture ASTM standards

• ASTM F782-19 – Standard specification for doors, furniture, marine
• ASTM D3751 – Standard Practice for the evaluation of furniture polish
• ASTM F1550 – 16 – Standard test method for fire-test-response of furniture

You can find additional relevant ASTM standards specifically for your wooden furniture on the official website.

ASTM testing

ASTM testing requires advanced test equipment and professional knowledge. Importers don’t need to know all details about standards and perform testing on their own, instead, established lab testing companies such as SGS, QMIA or Intertek, can provide ASTM testing services.

Product Packaging

Other than wooden furniture compliance, importers will also need to ensure that the product packaging is compliant when importing to the United States. Here is the overview of packaging requirements.

Heavy Metals Restrictions

The packaging materials must comply with the Fair Packaging and Labeling Act (FPLA) and Uniform Packaging and Labeling Regulation (UPLR). Heavy metals such as cadmium, lead, and mercury, are restricted under these regulations.

Therefore, you must verify whether your product packaging is compliant when entering the United States. Testing companies such as SGS, TUV, and Intertek can also provide packaging testing services to ensure compliance.

Labeling Requirements

Importers shall also include other product labeling requirements such as country of origin and compliance marks on the product packaging, as required.