The Ultimate Checklist for Cal TB 117-2013

At the end of 2020, Congress passed the Consolidated Appropriations Act (Cal TB 117-2013), which went into effect on June 25, 2021. Section 2101 of the Act states that after June 25th, upholstered furniture — Items manufactured, imported, or reupholstered on or after that date — must pass Cal TB 117-2013. To be specific, the Cal TB 117-2013 testing standard is a cigarette smolder test. Once the furniture is manufactured, it must be affixed with a permanent tag including the statement: “Complies with U.S. CPSC requirements for upholstered furniture flammability“.

As our entire industry is rebounding from the effects of COVID-19, it can feel like there is an overwhelming amount of information hidden within the Consolidated Appropriations Act. As one of the premier finishing and testing operations in the country, SBI is here to educate and provide updates to individuals and the community at large on how this affects us. Below you will find a summary of the changes, helpful recommendations, and a list of requirements needed in order to maintain compliance:

1. All residential and contract upholstered furniture, as defined by the act, must pass Cal TB 117-2013. This includes pillows and accessories.
2. This mandate will take effect on June 25th, 2021.
3. All residential and contract furniture is required to include a conspicuous and legible permanent label that states “Complies with the U.S. CPSC requirements for upholstered furniture flammability.” (more details andexamples found here)
4. Upholstered furniture will be required to withstand a “smolder test” and be smolder resistant, rather than an “open flame” standard, which was in place prior to Cal TB117-2013.
5. Upholstered furniture will require a permanent label, therefore they will not be required to include a General Certificate of Conformity. The permanent label will act as the certification that the product complies with Cal TB 117-2013.
6. The responsibility for ensuring products comply with these requirements for upholstered furniture falls on manufacturers, importers, and reupholsterers.
7. This law does not apply to bedding products, including mattresses and foundations (which are already subject to separate federal flammability standards). (more specifics found here)

1.  Companies should evaluate their current inventory and consider testing and labeling any furniture that will not sell before June 25th, 2021. It is not clear if this law will allow any “sell-through” time where companies may sell products that have not yet been tested or labeled.
2. Across the board, companies should begin communicating with all upstream suppliers and manufacturers to inform them of the new law and its requirements.
3. Proactively create processes to ensure compliance, starting with adding steps to quality assurance and audit policies so it becomes part of the organizations routine.
4. With regard to record-keeping and compliance of these certifications (in addition to labels mentioned above), a best practice is to maintain records for at least as long as the product remains in production.

There is a lot of information to digest here, and updates continue to be released as we get closer to June 25, 2021. SBI is closely monitoring all developments with the Consolidated Appropriations Act, and we take our responsibility as a fabric finishing and testing operation very seriously. In addition to this general guidance, we offer all approved testing services, and our entire business revolves around providing top-of-the-line, full-service fabric finishing solutions to meet and exceed industry standards 

Our industry is in this together, so please email compliance@sbifinishing.com or call (903) 675-1440 with any questions you may have about the Consolidated Appropriations Act. As more information becomes available, we will keep the industry updated via our website and LinkedIn page. 

For more information about the Title XXI – COVID-19 Regulatory Relief and Work from Home Safety Act, CLICK HERE.