Upholstered Furniture Smolder Resistance and Certification Labeling

The rule concerns defined upholstered furniture, including covered reupholstery work. Its scope is not determined merely by whether an item contains foam or textile. Examine the intended seating use, construction and the regulatory exclusions. Mattresses have separate flammability standards, and an article’s decorative description does not settle whether its upholstered seating construction falls within part 1640.

Part 1640 incorporates California TB 117-2013, which addresses smolder resistance of materials used in upholstered furniture. The federal incorporation identifies the governing edition; a later state document does not automatically amend the federal rule. Read the bulletin through the official availability information in the regulation. This record summarizes its subject and does not reproduce the detailed apparatus and specimen procedures.

The bulletin addresses cover fabric, resilient filling, barrier and decking materials. CPSC describes compliant constructions using passing cover and filling materials, or a passing barrier fully surrounding the filling, with the decking requirement addressed when present. Preserve the actual layer arrangement and component identities. A report for one cover fabric cannot establish that every untested combination of filling, barrier and decking is compliant.

Section 1640.4 states that the covered fabric, material or product is not subject to CPSA section 14(a) with respect to this standard. Instead, the manufacturer places the prescribed certification statement on a permanent product label. The statement is: “Complies with U.S. CPSC requirements for upholstered furniture flammability.” This specific arrangement should not be replaced by an indiscriminate demand for a GCC solely for part 1640.

Retain the component reports, supplier specifications and construction information supporting the compliance statement. CPSC identifies retaining such information as a practical compliance measure; do not misstate a recommended retention practice as an invented federal retention term. The label must remain attached through merchandising and distribution to the consumer. A removable hangtag or zip-tied card is not the permanent label contemplated by the guidance.

Reupholstery businesses must consider added cover and filling materials within the applicable scope. Manufacturers should review substitutions that affect the assessed construction. Other requirements, such as lead paint, structural safety or state provisions addressing different risks, may remain relevant. The federal smolder standard does not establish an unrestricted fire rating, authorize a private certification mark or indicate government approval of a furniture model.