Imagine you’re a small pillow manufacturer that finally lands a major wholesale account with a regional home goods retailer. The labels arrive on time, production moves forward, and everything seems fine until someone on the retailer’s receiving team pulls a pillow off the line and notices the fill material listed on the label doesn’t match the fill used in the product. 

To add insult to injury, the registered identification number is also wrong. The entire shipment gets flagged, the retailer threatens to pull the account, and the manufacturer is suddenly looking at an expensive reprint, a compliance headache, and a damaged business relationship all because a proof was rushed through without a second look.

A transposed number, an outdated fill description, a registration detail that never got updated after a supplier change — these are small errors that carry real consequences when they make it onto a finished law label. The proof is the step that catches them before they do. If you’ve ever wondered why we require an approved proof before any order goes to press, here is exactly what that process looks like and why every part of it matters.

What a Label Proof Is and Why It Exists

A proof is a digital preview of exactly what your label will look like when it comes off the press. Before anything gets printed, you get to look over every detail. You see your fill content description, registered identification number, contact information, and your layout. Then you either give us the go-ahead or ask for changes.

We require proofs because printing is a one-way process. Once ink hits the material, there is no going back. The proof is your chance to catch anything that needs fixing before that happens. It also creates a clear, documented record of what both you and our team agreed to produce — which protects everyone involved.

How Our Label Artwork Proofing Process Works

Our process is quite straightforward! Here’s what happens between the moment you reach out and the moment your labels go into production: 

Step 1: You Submit Your Label Information

Everything starts with your artwork details. You have a few options for getting us what we need:

• Complete our online submission form — the fastest way to get the ball rolling
• Request our physical form via email — just ask and we will send it over
• Provide existing artwork — if you already have a label design and want a refresh or full redesign, we will work from what you have

No matter how you come to us, this first step makes sure our design team has everything they need to build your label correctly.

Step 2: We Design Your Artwork and Send It Over for Review

Once we have your information, our design team gets to work. When the artwork is ready, we send it to you through our proofing software, not just a regular email attachment.

This tool is built specifically for reviewing and approving label artwork. Here is what you get with it:

• A clear digital preview of your label exactly as designed
• A simple way to approve the proof when everything looks good
• A way to request changes directly in the system if something needs adjusting, no email back-and-forths
• Automatic daily reminders if the proof has not been reviewed yet, so your order doesn’t get held up
• A saved record of your approval that stays on file, so there is always documentation of exactly what was approved and when

That last one is important! If a question comes up during an audit or compliance review down the road — “Was this the version we signed off on?" — the answer is right there, timestamped and ready.

Step 3: We Get Your Artwork Ready for the Press

After your proof is approved, our team does the technical work needed to take your design from a digital file to a press-ready layout.

Since we print multiple labels on a single sheet, everything has to be laid out precisely. That includes:

• Removing placeholder borders that were in the design file but will not appear on the finished cut label
• Adding bleed lines so your design runs all the way to the edge of the label without any gaps
• Adjusting toning and shading so colors print accurately on our equipment

You do not need to do anything here, we take care of all of it. But knowing this step exists helps explain why having a clean, approved proof to work from makes such a difference in the finished product.

Step 4: Your Order Goes Into Production

Once the layout is ready, your order moves into our production queue. Here is a general idea of what to expect after proof approval:

• Smaller orders: 2–3 business days
• Larger orders: 3–5 business days

We’ll keep you updated along the way!

A Few More Things Worth Knowing

We Check Your Label for Compliance on Every Order

As part of our design and review process, we look at every label against uniform packaging and labeling regulations. For manufacturers of mattresses, pillows, furniture, and stuffed articles, these requirements can get detailed and our team flags anything that looks off before it becomes a real problem.

Here is how it works depending on your situation:

• If we designed your label, we make sure it meets compliance standards before it ever reaches you for review.
• If you are providing your own artwork, we look it over and let you know if we spot anything that does not meet the requirements.

This is a courtesy. We share what we find, and the decision of what to do with that information is yours. You can update the design, or you can move forward as-is. We just want to make sure you have the full picture before you approve.

You Still Need a Proof Even If You Supply Your Own Artwork

A lot of customers assume that if they are handing us a finished, print-ready file, the proofing step does not apply to them. That’s not quite how it works. 

Moving a file into a professional printing environment often requires small technical adjustments to get the best results. Those might include:

• Pantone color matching — making sure your digital colors translate accurately to the printed label
• Print margin adjustments — confirming that all your text and key details are within safe zones so nothing gets cut off

These are small tweaks, but they can change how your label looks on the finished product. The proof makes sure you see those adjustments before anything goes to press.

Read Your Proof Carefully — Every Time

We put real care into reviewing your artwork, but the proof is your review too. Once you approve it, you’re taking responsibility for what is on that label. If a fill material description is outdated, a registration number has a digit wrong, or a required field is missing — and it was in the proof you approved — that is how the label will print.

Before you click approve, it is worth going through everything line by line:

• Registered identification number is accurate and current
• Fill content description matches your actual materials
• Country of origin is correct
• Business name and address are accurate
• All required law label fields are present and complete
• Colors and layout look right
• Nothing appears cut off or out of place

Need Help With Your Label Design? We Can Take It Off Your Plate.

If you do not have existing artwork — or you are ready for a label that looks more polished and professional — our design team can handle the whole thing for you.

Label Design Service: $175

This includes a complete custom artwork design and a digital file sent straight to you. No print order required.

Whether you are launching a new product line, updating labels after a material change, or just ready to move on from a design that has seen better days, we will create something that is print-ready, compliance-informed, and a good representation of your brand.

Request a free quote today!

The Bottom Line

The proof exists for one reason: to make sure you get exactly what you approved. Every part of our process — the proofing software, the compliance check, the print preparation — is built around making that happen reliably, every time.

If you have questions about how any of this works or want to get started on your next label order, get in touch. We’re happy to help!

An hour later, the fabric is discolored, the cushion filling is waterlogged, and they’re filing a complaint and leaving a review that’ll live on the internet forever.

You could add two lines of text on your label and never have to worry about this!

Scenarios like this are more common than manufacturers like to admit. Care and cleaning instructions on furniture and stuffed goods law labels are a courtesy to consumers, a liability shield, and – depending on the state – a compliance requirement. 

Whether you’re producing upholstered sofas, accent chairs, throw pillows, or stuffed toys, here’s what you need to know about including proper care instructions on your law labels.

Why You Should Put Care Instructions Labels On Your Stuffed Items

Furniture and stuffed goods are required by law to carry a law label disclosing their filling materials. But care instructions serve a different function: they tell the consumer how to clean and maintain the product without damaging it.

When care information is vague, missing, or wrong, the consequences land squarely on your brand. Damaged upholstery, ruined fillings, and voided warranties are all downstream effects of inadequate care guidance. And in states like California, care labeling requirements for certain textile products go beyond the federal baseline, something worth reviewing before you finalize your label copy.

What Care Instructions Should Cover

For upholstered furniture and stuffed goods, care instructions should address every cleaning method a consumer might reasonably attempt and flag anything that would cause damage. 

In practice, that means that every label should address: 

Cleaning Method

Can the item be spot cleaned? Hand washed? Machine washed (for removable covers)? The label should state the appropriate method clearly. If certain methods — saturating the fabric, steam cleaning, machine washing the entire piece — would cause damage, that needs to be disclosed explicitly. “Spot clean only" and “Do not saturate" are both examples of instructions that protect the consumer and your product.

Temperature

For any cleaning method that involves water or heat, temperature matters. A fabric that holds up fine under cool water may shrink, bleed, or distort with warm or hot water. If your upholstery fabric has temperature sensitivities, say so.

Drying

Furniture and stuffed goods have filling materials that react very differently to heat and moisture than apparel does. Down, polyester fiberfill, foam, and natural fibers each have their own drying requirements. If a cushion cover can go in the dryer, specify the heat setting. If it must be air dried — or if the filling must never get wet at all — that’s critical information for the consumer.

Ironing

For removable textile covers, ironing guidance may be relevant. If the fabric can be ironed, indicate the appropriate temperature. If ironing would damage the material (common with certain synthetic upholstery fabrics), that warning belongs on the label.

Warnings

This is where many manufacturers underinvest. Any cleaning process that would harm the product — bleach, steam, dry cleaning solvents, excessive moisture — needs to be explicitly called out. Don’t assume consumers will intuitively know what not to do. If it can go wrong, say so.

Dry Cleaning: Be Specific About What’s Safe

If your product or its removable components can be dry cleaned, a simple “Dryclean" statement may be sufficient. But if any part of the dry cleaning process would damage the item — for example, if steam pressing would distort cushion structure, or if certain solvents would affect the fabric or filling — that limitation must be disclosed.

This is especially relevant for upholstered goods with structured forms, specialty fabrics, or mixed-material constructions. A blanket “Dryclean" instruction on a product that can’t withstand steam is an incomplete label and a potential liability if the consumer follows the instruction in good faith and the product is damaged.

Products with Multiple Components: Label Each One

Many furniture and stuffed goods have components with different care requirements — a sofa with removable cushion covers, a decorative pillow with an embellished outer shell and a separate insert, or a stuffed toy with surface-applied details that can’t get wet.

Best practice is to disclose care instructions for each component separately when they differ. A single label that says “Machine wash cold" when that instruction only applies to the cover — not the insert — is setting consumers up for a mistake. The goal of care information is to give the consumer everything they need to properly clean the item without causing damage or reducing its lifespan.

This is a nuanced area, and one where it pays to think carefully about how your label is written. For guidance on handling multi-component products more broadly, check out our article on labeling products with removable components.

Using Care Symbols: Know Which Standard Applies

If you prefer to use care symbols rather than written instructions, make sure you’re working from the right standard. In the U.S., the permitted standard for care symbols on textile products is ASTM Standard D5489-96c. Non-standard or internationally-sourced symbols may not satisfy U.S. requirements, and using them inconsistently across a product line creates its own compliance headaches.

If your products are sold in multiple countries, be aware that U.S. care symbols differ from the ISO symbols used in many international markets. Get clear on which standard applies where, and make sure your label reflects it.

Don’t Forget California

If you sell furniture or stuffed goods into the California market — and most manufacturers do — California has additional labeling requirements layered on top of federal standards. The state has historically been more prescriptive about product labeling across multiple categories, and textiles and upholstered goods are no exception.

It’s also worth knowing that California’s Proposition 65 warning requirements can apply to furniture products depending on the materials used in their construction. 

Get Your Labels Right Before They Go to Print

Care instructions are one of those label elements that are easy to underestimate, until a consumer damages a product and you’re explaining why the label didn’t warn them. The good news is that getting this right isn’t complicated when you know what to include.

Accurate, specific, product-tested care instructions protect your customers and your brand. Vague or missing instructions do the opposite.

If you’re building out labels for a new furniture or stuffed goods line, updating existing labels, or want a professional eye on your current compliance posture, we’d love to help! From law label design and printing to compliance audits and hands-on consulting, we work with manufacturers every day to make sure their labels say exactly what they need to say — no more, no less.

The answer isn’t one-size-fits-all and getting it wrong can expose your business to some serious compliance risk.

Below, we’ll break down exactly how to approach law labeling for products with removable or detachable components, with real-world examples to make the rules as clear as possible.

What Goes Into Law Labeling for Multi-Component Products 

Law labels are a legal requirement in the United States for filled products like mattresses, pillows, upholstered furniture, and stuffed toys, governed by individual state regulations. Every label must disclose the filling materials used. And when a product has multiple distinct filled sections, the stakes get a little higher.

The challenge with removable components is that regulators want consumers to have accurate material information for every part of what they’re buying. If a customer removes a cushion and loses the main label, do they still know what’s inside? That’s really the core question driving these rules.

The Key Question: Does Your Product Have a Main Filled Body?

Here’s the most important thing to figure out before anything else: does your product have a main filled body — sometimes called the “shell" or “frame" — that’s distinct from its removable components?

Here’s the general rule of thumb:

• If your product has a main filled body, removable components like cushions or inserts can be disclosed on a single label using sectional disclosures.
• If your product has no main filled body and consists entirely of fully detachable parts, each component needs its own law label.

This distinction is really the backbone of compliant labeling for multi-component products, and it applies across furniture, juvenile products, and more.

Combined Labels: When One Label Can Cover Multiple Components

Let’s walk through the most common example in the industry: sofas.

A standard sofa typically has a main filled body (the frame and base structure), plus removable back cushions and seat cushions. In this case, all components can be disclosed on a single law label using a sectional format. You’ll need to list the number of cushions for each section alongside the material breakdown.

Here’s what that looks like in practice:

BODY: POLYURETHANE FOAM PAD — 100%

BACK CUSHION: (2) POLYURETHANE FOAM PAD — 60% POLYESTER FIBER BATTING — 40%

SEAT CUSHION: (2) POLYURETHANE FOAM PAD — 70% POLYESTER FIBER BATTING — 30%

If throw pillows are sold as part of the sofa set, you can add those to the combined label with their own sectional disclosure.

Other products that commonly qualify for the combined label format include:

• Car seats (main seat body + removable inserts or head supports)
• Play yards and cribs (main frame + removable mattress pad or bassinet insert)
• Sectional sofas (frame + individual seat and back cushions)

The combined format simplifies your supply chain and keeps your compliance documentation in one place, which is a meaningful operational win. 

Separate Labels: When Every Component Needs Its Own Label

Now let’s look at the flip side. Consider an outdoor sofa or a modular seating set where there’s no main filled body. Instead, the whole product is made up of individual seat cushions, back cushions, and maybe throw pillows — each fully detachable from one another, with no permanent filled frame holding it together.

In that scenario, the combined label format is not acceptable. Each component has to carry its own law label disclosing only the filling materials in that specific piece:

• The back cushion(s) get a label listing only back cushion materials.
• The seat cushion(s) get a label listing only seat cushion materials.
• Any throw pillows sold with the set each need their own label too.

This requirement exists because without a central body anchoring the product, there’s no logical “home base" for a single compliance label. Each piece could be separated, resold, or used on its own, so each piece needs to stand alone from a regulatory standpoint.

And honestly, this is where a lot of manufacturers run into trouble. A combined label on a fully modular product feels like it should be fine but it isn’t, and audits or retailer compliance reviews will catch it. 

The Connecticut Exception

Even when your product qualifies for the combined label format, there’s one more thing you’ll want to factor in before moving forward.

The written laws of the State of Connecticut require that each removable component be labeled separately, regardless of whether a main body is present. Connecticut is currently the only state with this specific written requirement, but it’s a significant one if your products are sold there.

That means your company needs to do a risk assessment before leaning on the combined label format for products with detachable components. Some things worth thinking through:

• How much of your product volume ships into Connecticut?
• Where do your retail partners distribute?
• How feasible is it to produce component-specific labels?
• What’s your exposure if a state inspection or consumer complaint surfaces?

For many manufacturers, the safest move is to label each component separately from the start, especially if you’re distributing nationally and can’t easily control where your product ends up on the shelf. 

Match Your Label Format to Your Product Structure

When it comes to law labeling for products with removable components, it really does come down to one foundational question: Does your product have a main filled body?

If yes → a combined sectional label is generally your best path forward (just keep that Connecticut exception in mind).

If no → you’ll need separate labels for each detachable component.

Getting this right protects your brand, keeps you on the right side of state regulations, and keeps your retail partners happy. When in doubt, don’t guess; We’re happy to help!

But Prop 65 warning labels can apply to virtually any consumer product—food, personal care items, electronics, tools, household goods, and more—whenever a product can expose someone to a listed chemical above California’s “safe harbor” levels. And it doesn’t matter where the product is made: manufacturing outside California doesn’t exempt you from Prop 65 if you sell into California.

Let’s break down what Prop 65 is really asking for, what a compliant label needs, and how to avoid expensive mistakes.

What Proposition 65 Requires + Who It Applies To

Proposition 65—formally the Safe Drinking Water and Toxic Enforcement Act—is a California law that requires businesses to provide “clear and reasonable” warnings before exposing people to significant amounts of chemicals that are listed for cancer and/or reproductive harm.

A few key points that trip up even experienced brands:

• It’s exposure-based. The trigger isn’t “your product contains a chemical,” it’s whether typical use can expose consumers above safe harbor levels.
• It’s product-category agnostic. The law isn’t aimed at any one industry; it’s used across categories.
• It’s California-driven, but market-wide. If your company distributes nationally or sells online, rather than trying to geofence compliance; try complying broadly to the market as whole!

If you’re already navigating other labels (law labels, TB-117, TSCA Title VI, tracking labels, etc.), Prop 65 is often one more compliance layer that needs to be integrated cleanly—sometimes literally on the same tag. (This is exactly why “combined label” strategies have become so common.)

Why Prop 65 Shows Up Everywhere

Here’s the simplest way to think about Prop 65: California wants consumers to have a heads-up when a product may add to lifetime risk of cancer or reproductive harm from chemical exposure. Which is valid!

That’s why you’ll see Prop 65 warnings on an enormous range of products—including categories that surprise people:

• Electronics (metals, plasticizers, flame retardants, etc.)
• Personal care (certain ingredients, contaminants, packaging exposures)
• Tools & hardware (dusts, metals, solvents)
• Vehicles, parts, and marine products (operation, handling, servicing exposures)

And yes, furniture is a frequent repeat offender, because certain materials and treatments are common, and exposures can be meaningful enough to trigger warnings.

If you want a quick “zoomed-out” way to sanity check your labeling universe, our guide on what type of label your product needs is a helpful starting point—especially if you’re stacking multiple regulatory requirements.

The Most Common Prop 65 Chemicals We See: Formaldehyde + Wood Dust

In our experience, two chemical callouts come up constantly for furniture and wood-related goods:

Formaldehyde 

Formaldehyde is listed under Prop 65 because it can cause cancer, and it can be relevant when products emit formaldehyde gas (often associated with certain resins used in composite wood products). 

Wood dust 

Wood dust is listed under Prop 65 because it can cause cancer. And exposure can occur during cutting, sanding, manufacturing, or even certain consumer uses/maintenance.

Also worth noting: OEHHA provides sample warning language that includes how to format warnings when chemicals are listed for both cancer and reproductive harm. This “safe harbor” structure is what most brands aim to match so they’re not reinventing the wheel.

Prop 65 label requirements

This is where people lose time (and sometimes reprint budgets).

A compliant Prop 65 warning label generally needs:

1) The warning symbol

The symbol is a black exclamation point inside a yellow equilateral triangle with a bold black outline, placed to the left of the warning text. If the product label isn’t printed using yellow, the symbol may be black and white.

2) Standardized signal word + warning language

OEHHA provides standardized “safe harbor” content options (full-length and short-form) depending on product type and chemical listing status.

3) Chemical name(s) (when required)

Many warnings require naming at least one listed chemical. OEHHA’s sample warnings show how chemical names are inserted into the standardized language.

4) A Prop 65 website link

OEHHA’s warnings typically point consumers to the official site for more information.

OEHHA also maintains product/category pages (for example, furniture and passenger vehicles) that businesses commonly reference for product-specific context.

5) Font size + prominence rules

Prop 65 warnings must be conspicuous. The regulations include type-size requirements and minimums (often discussed as “no smaller than the largest type used for other consumer information,” with a 6-point minimum noted in regulatory text and guidance).

If you’re juggling multiple labels on one product (law label + TB-117 + 16 CFR 1633 + Prop 65), it’s easy to accidentally violate one label’s formatting rules while trying to satisfy another. American Law Label’s article on combined product labels is a solid overview of how to consolidate without creating a compliance mess.

Penalties + Practical Next Steps 

Prop 65 enforcement is not the place to gamble. California states that penalties for failing to provide required warnings can be as high as $2,500 every violation per day.

A practical, low-drama workflow

1. Identify likely exposure drivers (materials, coatings, adhesives, dust-generating use)
2. Confirm which warning format applies (consumer product vs. other contexts; full-length vs. short-form options)
3. Build label art that matches the symbol/color/font rules
4. Document your basis (so you can answer retailer/compliance questions quickly)
5. Print labels that hold up (because flimsy labels create their own kind of problem)

Need Prop 65 labels printed? We can help. 

American Law Label can provide sewn-in and adhesive (sticker) Proposition 65 labels that meet California requirements:

• Sewn-in labels: turnaround time 2–3 business days
• Sticker labels: turnaround time 5–7 business days

If you want a quote, reach out and tell us:

• product type
• label format needed (sewn-in vs. sticker)
• quantity
• whether you’re combining Prop 65 with other required labels

We’d love to help you stay compliant!

“Some of it’s made overseas, but we do work on it here. Can we add that “Made in USA” label?”

It’s a reasonable question. It’s also one of the most common ways well-meaning companies stumble into compliance trouble.

The confusion usually comes from mixing two different regulatory frameworks. U.S. Customs and Border Protection focuses on country-of-origin marking for imported goods, while the Federal Trade Commission focuses on whether U.S.-origin claims are truthful and non-misleading to consumers.

Both matter and they overlap. But they’re not the same and your labels need to satisfy both.

What Customs Requires for Imported Products

From a Customs standpoint, the expectation is clear: every article of foreign origin entering the United States must be legibly marked with the English name of its country of origin, unless a specific legal exception applies. This means that a stuffed toy made in Germany can’t be marked “Deutschland” and a pillow made in Sweden can’t be marked “Sverige.” The marking must be sufficiently permanent and visible to inform the ultimate purchaser.

This requirement exists regardless of marketing goals. Customs is not evaluating whether a product feels “American” or whether it includes some U.S. labor later in the process. Its role is disclosure. If a product is considered foreign origin for Customs purposes, the country-of-origin marking must appear.

Where importers and manufacturers often get tripped up is assuming that domestic assembly, filling, or finishing automatically overrides this requirement. It doesn’t. If a product is imported or deemed foreign origin, that marking obligation still applies — even when meaningful work happens in the U.S. after importation.

What the FTC Means by “Made in USA”

Once you choose to make a U.S.-origin claim on a label, hangtag, website, or other marketing material, the FTC’s rules apply.

According to FTC guidance, an unqualified “Made in USA” claim is only appropriate when a product is “all or virtually all” made in the United States. This means that the significant parts, processing, and labor must be of U.S. origin, with only negligible foreign content.

Final assembly in the U.S. alone does not meet this standard and neither does packaging, labeling, or light processing. If a product includes imported materials or components that play a meaningful role in the finished item, an unqualified “Made in USA” claim is typically not allowed.

This standard exists because consumers reasonably interpret “Made in USA” to mean the product is essentially American-made from start to finish and the FTC evaluates claims based on how they are likely to be understood, not on intent.

When Qualified Claims Are the Right Answer

For many importers and manufacturers, the most accurate and defensible approach is a qualified Made in USA claim.

A qualified claim explains the extent, type, or location of U.S. involvement while clearly indicating that the product is not entirely of domestic origin. The FTC specifically allows these claims when they are truthful, substantiated, and limited to the actual process or components involved.

In practice, this often looks like language such as:

• Assembled in USA
• Filled and Finished in USA
• Made in USA of domestic and imported parts
• Made in USA of domestic and imported materials

These statements work because they are specific. They highlight legitimate U.S. work without implying that the entire product meets the “all or virtually all” standard.

The FTC is also explicit that claims about specific processes or parts must not be framed in a way that suggests broader U.S. origin than what actually exists.

This is where vague patriotic language or imagery can create risk. Even without words, symbols like flags or maps can imply an unqualified claim depending on context.

Why Accuracy Matters More Than Ever

Consumer interest in “Made in USA” remains strong, but research shows that understanding of what the claim legally means is often incomplete. A Michigan State University study on U.S. country-of-origin labeling found that many consumers assume “Made in USA” means entirely domestic production, even when products include imported components. The researchers noted that this gap between consumer perception and legal reality increases the likelihood of misleading claims in modern supply chains.

Because origin claims can influence buying behavior, the FTC has made clear that it actively enforces the Made in USA standard.

In 2022, the FTC ordered Lions Not Sheep Products to pay $211,335 in civil penalties after the company was found to have removed “Made in China” tags from apparel and replaced them with “Made in USA” labels. The case made it clear that physically altering labels to imply U.S. origin without meeting the standard is a direct violation of FTC rules.

These cases are not outliers. They reflect an active enforcement posture that importers and manufacturers should factor into label decisions.

A Law Label Detail That Often Gets Missed

When law labels are involved, there is an additional nuance that matters.

Regulating agencies expect the country-of-origin statement on a law label to align with the suffix of the URN (Unique Registration Number). The URN suffix corresponds to the state or country where the manufacturing facility is registered.

For example, a URN ending in “CN” is registered to a China-based facility. A country-of-origin statement such as “Made in USA” would be inappropriate on that label.

It’s also important to understand that state agencies reviewing law labels do not verify Made in USA claims. Their review focuses on required disclosures and formatting, not on whether a product qualifies as wholly or partially U.S.-made. That means a label can be approved and still present FTC risk if the origin language overstates U.S. content.

Alignment across Customs rules, FTC guidance, and law label registration details is essential, especially when labels are combined.

Before You Print: A Practical Way to Think About Origin Claims

Before approving artwork, it helps to pause and ask a few grounding questions. Are you making an unqualified or qualified claim? Does the wording accurately reflect what actually happens in the U.S.? Does the country-of-origin statement align with the URN suffix? And could you substantiate the claim if asked?

Answering those questions upfront can prevent costly reprints, enforcement exposure, and retailer pushback later.

Highlighting True “Made in USA” Products? We Can Help 

If your products truly qualify for an unqualified “Made in USA” claim, we make it easy to highlight that clearly and professionally.

We keep sew-in tritext (1.25" x 1") MADE IN USA American flag labels in stock and can order in tyvek labels as well. They’re a simple way to call out domestic origin without redesigning your entire label system — and they’re available with same-day turnaround.  Request a quote today and we’ll help you get exactly what you need!

They’re not being dramatic. 

California’s Technical Bulletin 117-2013 (TB-117-2013) began as a state-level flammability standard, but it now serves as the foundation of U.S. residential upholstered furniture flammability requirements. If the label is wrong—or missing—your products can be delayed at port, pulled from retail floors, or flagged by state investigators. 

Today, we’re breaking down what TB-117 is, which products it applies to (and which it doesn’t), what must appear on your TB-117 label, and how the required CPSC federal flammability statement fits into the compliance picture. 

Why TB-117 Exists and Why It’s So Strict 

TB-117 is California’s smolder-resistance standard for residential upholstered furniture. It sets performance requirements for cover fabrics, filling materials, barrier materials, and decking materials sold in the state. Since January 1, 2015, every piece of upholstered furniture product sold in California must comply with the test method and carry the appropriate flammability label. The federal government later adopted TB-117-2013 through 16 CFR part 1640, making it the national flammability standard for upholstered furniture. 

Why the urgency? Research has consistently shown that upholstered furniture fires are low-frequency but high-fatality events. Fires in which residential upholstered furniture (RUF) was the first item ignited accounted for 16% of US residential fire deaths. TB-117-2013 addresses this risk by requiring smolder-resistant materials and clear labeling so manufacturers, inspectors, and consumers know how a piece of furniture is built.

Who Must Use TB-117 Labels? Understanding Coverage and Exemptions 

TB-117-2013 applies to residential upholstered furniture sold in California: sofas, chairs, upholstered headboards, ottomans, and similar products designed for sitting or lounging. These items must meet the smolder resistance requirements and carry the proper TB-117 label. 

But not all products fall under TB-117. California lists several important exemptions, and this is one place manufacturers often make mistakes.

TB-117-Exempt Items 

• Bedding products such as mattresses, mattress pads, comforters, decorative pillows, and bed pillows 
• Cushions and pads intended solely for outdoor use 
• Articles with ½ inch or less of filling material and no horizontal surface meeting a vertical surface 
• Certain children’s products such as bassinets, car seats, changing pads, highchair pads, infant carriers, walkers, playpen side pads, strollers, and similar items 
• Medically prescribed or therapeutic upholstered items made for a named individual 
• Upholstered furniture used strictly in motorized RVs (but not towables, trailers, or campers) 
• Furniture used exclusively for fitness and exercise 

If you sell across multiple product categories—mattresses, pillows, and furniture—these distinctions matter. Here’s a refresher on mattress flammability labeling! 

TB-117 Label Requirements: Size, Permanence, and Chemical Disclosures 

If your furniture falls under TB-117, the label must meet specific requirements. The flammability label must be at least 2 × 3 inches, permanently attached, and made of a material that won’t tear or deface easily. 

The Flame Retardant Statement (SB 1019) 

TB-117 labels must also disclose whether flame retardant (FR) chemicals were added to the product. Manufacturers must place an “X” in one of two checkboxes indicating FR was added or no FR was added. 

This requirement is rooted in research on flame retardant exposure. Studies show fire retardant chemicals can migrate into household dust, creating potential health risks—especially for children. At the same time, newer research has explored how barrier technologies and construction methods can increase smolder resistance without relying heavily on FR additives, making the statement even more relevant for consumers and regulators. 

Why You Should Never Over-Label 

If you add a TB-117 label to a product that isn’t covered—such as a decorative pillow—California investigators are still authorized to inspect the label. If the wording or structure is incorrect, they can issue violations even though the product is exempt. 

In other words: never add a TB-117 label “just in case.” 

The CPSC Certification Statement: A Federal Requirement on Upholstered Furniture 

When California’s TB-117-2013 became the federal standard, the CPSC added its own labeling rule. Under 16 CFR 1640.4, any item of upholstered furniture covered by TB-117-2013 must also include the following statement on a permanent label: 

“Complies with U.S. CPSC requirements for upholstered furniture flammability.” 

The certification label must have a white background, black text, a black border, and appear on the front of the tag in English. 

Because furniture already carries law labels like TB-117 labels, and sometimes Prop 65 or TSCA statements, many brands use a combined product label to consolidate required language into one clean format. 

How to Avoid Common TB-117 Mistakes 

TB-117-2013 and the CPSC certification statement aren’t optional, they’re core compliance requirements for any upholstered furniture sold in the U.S. Getting them wrong can delay shipments, trigger state violations, or cause retailers to refuse your product. 

TB-117 Compliance Checklist for Furniture Manufacturers 

• Confirm which of your products fall under TB-117 and which are exempt 
• Ensure TB-117 labels meet size, material, and attachment requirements 
• Verify the flame retardant chemical statement is clear and accurate 
• Include the mandatory CPSC certification statement on every covered item 
• Avoid over-labeling exempt products such as decorative pillows or children’s items 
• Review label materials to ensure long-term durability and state compliance 
• Consider a combined product label if your products require multiple regulatory tags 

If you want help reviewing or designing compliant TB-117 or CPSC flammability labels, we’re always happy to assist. A quick audit now can prevent expensive relabeling or enforcement issues later! 

We understand how complicated car seat compliance can be, especially when deadlines bump up against the holidays. Between law labels, children’s product tracking labels, and product registration cards (PRCs), there’s a lot to keep straight. And timing matters more than ever this time of year!

Here’s what every car seat manufacturer should know as we head into the busy season.

Understanding Federal Regulations for Car Seats

Children’s car seats are among the most heavily regulated products sold in the U.S. and for good reason. The combination of federal safety standards and CPSC labeling requirements ensures that every seat on the market meets rigorous performance and traceability expectations.

At the federal level, the National Highway Traffic Safety Administration (NHTSA) oversees Federal Motor Vehicle Safety Standard (FMVSS) 213, which sets performance requirements for car seats, booster seats, and restraint systems. These standards cover everything from crash testing to labeling instructions and warning placement. You can explore NHTSA’s guidance on FMVSS 213 here.

The Consumer Product Safety Commission (CPSC) also plays a key role. Under the Consumer Product Safety Improvement Act (CPSIA), all durable infant and toddler products—including car seats—must include both a children’s product tracking label and a product registration card. These requirements make it easier to identify and notify consumers in the event of a recall. If you’d like more background, the CPSC’s full overview of durable infant and toddler product rules is available here.

Children’s Product Tracking Labels: Small Tag, Big Responsibility

Every car seat sold in the U.S. must include a children’s product tracking label, as required under CPSIA Section 103. These labels help identify where and when a product was made—and by whom—in case a safety issue comes up later. A compliant tracking label includes:

• The manufacturer’s name
• Location and date of manufacture
• Batch or run number
• Contact information or website

Tracking labels have to be permanent, legible, and easy for consumers to find. They’re a small but essential part of any compliant car seat, ensuring traceability if a recall or consumer concern arises. You can read the CPSC’s guidance on tracking label requirements here.

At American Law Label, we design and print durable tracking labels that meet CPSC expectations and blend seamlessly with your other compliance materials. Whether you’re preparing for a new model launch or updating your production runs, having this piece right helps you avoid downstream headaches.

Product Registration Cards Keep Families Connected

Product Registration Cards (PRCs) might not get much attention on the factory floor, but they’re a big deal for safety. These cards allow parents and caregivers to register their car seat so they can be contacted directly in case of a recall or safety notice. Under CPSC and NHTSA regulations, PRCs must:

• Be attached to each car seat
• Include the manufacturer’s name, model number, and date of manufacture
• Be postage-paid and ready to mail
• Clearly explain why registration matters

The full CPSC overview of PRC requirements is available here. We handle both the design and printing of PRCs to make sure every card meets federal formatting and legibility standards. And because compliance details can change, our team monitors updates from CPSC and NHTSA so your materials stay current. We also offer free quotes on all label and card orders to help you plan your production timelines without surprises.

Plan Ahead For Holiday Printing Deadlines

As the holiday season approaches, production schedules tighten and carrier networks slow down. Planning ahead is the best way to avoid last-minute stress. Our standard turnaround times are 48-hour standard shipping on most label orders and next day for Priority Print Service for urgent projects.

During the holidays, shipping carriers may experience delays outside our control. We’ll always keep you updated if we receive notice that a shipment is running late, but the best defense is to get your order in early.

Our offices will be closed on November 27–28 for Thanksgiving Break, December 22–26 for Winter Break, and January 1 for New Year’s Day. We recommend submitting print orders well before those dates to avoid bottlenecks.

The earlier you confirm your quantities and designs, the smoother things go, especially if you need multiple label types or PRCs produced at once. Even with our quick turnaround, delivery times can stretch during peak season. Building in extra lead time now saves stress later and keeps your products moving on schedule.

If you’re planning to place an order before the holidays, now’s the time! Request a free quote today, and let’s make sure your labels arrive right when you need them.

Here’s a clear breakdown of what you need to know before sending your products to market.

Why Labeling Matters for Down/Feather Products

Consumers trust the word “down” to mean warmth, quality, and value. Regulators trust your label to be accurate, measurable, and verifiable. A misstep doesn’t just risk fines — it erodes customer confidence. That’s why testing, documentation, and precise label wording are essential.

U.S. Labeling Standards: When Can You Say “Down”?

In the United States, the word “DOWN” is tied directly to down cluster content.

• Minimum cluster percentage: To be labeled as “DOWN,” a product must contain at least 75% down cluster.
• Show your math: You must disclose the minimum percentage of down cluster on the label. For example:
  • “DOWN (MINIMUM 80% DOWN)”
• Minor wiggle room: To account for unavoidable variations in the manufacturing process, the US government allows a modest deviation of no more than 5% of the product’s actual percentage of down or other plumage. However, if the FTC finds that all or most of your products are 5% less than the stated percentage (e.g. most of your “50% down" pillows are actually 45% down), then the product must be relabeled to reflect the actual amount.

Example U.S. Labels

• Comforter: “DOWN (MINIMUM 85% DOWN)”
• Pillow: “DOWN & FEATHERS (50% DOWN, 50% WATERFOWL FEATHERS)"

Canadian Labeling Standards: More Than Just a Percentage

Canada takes a slightly different approach, defining what it calls “Commercial Down.”

• Composition rules: To qualify as “down,” the fill must meet this mix:
  • At least 75% down & plumules
  • No more than 25% small waterfowl feathers (≤ 60 mm, no quills)
  • No more than 20% fibers (feather + down fiber)
  • No more than 5% residue (including landfowl)
• Never say “100% down”: Labels can’t make that claim. Instead, every “down” label must include this statement:
  • “NOTE: This product contains an amount of feathers not exceeding that allowable by law.”
• Species claims come with rules: If you call it “goose down” or “duck down,” at least 90% of the fill must be from that species.

Example Canadian Labels

• Duvet: “DOWN (GOOSE)”
  • Plus the required note: “This product contains an amount of feathers not exceeding that allowable by law.”
• Pillow: “WATERFOWL FEATHERS” (meets Commercial Waterfowl Feather standards).

Key Differences at a Glance

The Down Compliance Checklist

Before printing your next run of labels, run through this quick list:

1. Test first: Verify cluster percentage, species makeup, and composition through an accredited lab.
2. Choose the right claim: Match U.S. cluster rules or Canada’s Commercial Down definitions.
3. Mind the disclaimers: Add Canada’s required note whenever you use “down.”
4. Be precise with blends: Both nations require precise blend information, with only minor variation allowed in the U.S.
5. Keep documentation: Store your lab results alongside label proofs for future audits.

When In Doubt Seek Us Out

Down labeling might feel like a maze of percentages and disclaimers, but the rules boil down to one principle: accuracy. If you test thoroughly and word your labels precisely, you’ll not only stay compliant — you’ll also build credibility with customers who expect transparency.

And if you sell in both the U.S. and Canada? Plan your label strategy early. Subtle differences like Canada’s mandatory note and species rule can save you costly relabeling later.

To ensure your labels meet the standards both in the U.S. and Canada – contact GRS and we will help you on your way.

What’s more, the type of registration you pursue will dictate key information that is printed on the law label. In this guide, we’ll cover the steps you need to pursue in order to print your preferred information on your product’s law label, including MADE BY, MADE FOR, IMPORTED BY, and DISTRIBUTED BY.

Before Getting Started

Only one company’s name can be printed on a law label: either the manufacturer or the importer. There are licensing requirements that come with both roles, discussed below.

In addition to the responsibility of licensing, the company you list on the product’s law label faces certain benefits and risks, including:

• Opportunity to build name recognition
• Responsibility for renewals
• Responsibility for fines/violations

A Quick Note on URNs

In addition to a proper license, every product needs a Uniform Registry Number (URN) printed on the law label. A URN is a unique identifier that traces the product back to the location where it was physically made.

URNs are only issued to manufacturers — they are never issued to importers, wholesalers, distributors or retailers (I/W/D/Rs).

MADE BY [COMPANY]

If you want to list the product’s manufacturer on the law label, your law label can say MADE BY [THE MANUFACTURER’S NAME]. This is the minimum requirement, as bedding and furniture laws primarily place the responsibility for the product on the manufacturer.

The manufacturer will need a Manufacturer License, which is a mandatory step in becoming compliant and selling stuffed articles in the United States.

What Will the Law Label Say?

URN 
The manufacturer’s name and address listed on the law label must match the name and address associated with the URN listed under “Reg No”.

MADE BY
Manufacturer’s Name
Manufacturer’s Address

MADE IN
The manufacturing location’s country.

Who Is the Manufacturer?

The manufacturer is the company that makes the bedding or upholstered furniture in whole or in part. This is the company that physically manufactures the product. 

The manufacturer must hold a Manufacturer License to legally sell stuffed articles in the United States.

Benefits and Risks of Manufacturer Licenses

The biggest benefit of a Manufacturer License is that it allows you to legally sell stuffed articles in the United States. Without one, your product cannot be sold in the U.S.

Unless the importer applies for another type of license (discussed below), the manufacturer’s company name and address will be printed on the product’s law label.

Manufacturer’s Licenses place all of the responsibility for registration and ongoing compliance on the manufacturer. However, if the manufacturer neglects to renew their license, the importer can still be at risk for violations and products being pulled from shelves without compensation if the importer is listed on the label.

How Do I Get a Manufacturer License?

Depending on the type of product, the manufacturer may need to register in up to fifteen (15) U.S. government agencies. Our sister company GRS can help you navigate the registration process for each location.

MADE FOR / IMPORTED BY / DISTRIBUTED BY [COMPANY]

If you want to list the product’s importer on the law label, your law label can say MADE FOR [THE IMPORTER’S NAME], IMPORTED BY [THE IMPORTER’S NAME], or DISTRIBUTED BY [THE IMPORTER’S NAME]. 

For any of these law label options, the importer will either need an Importer License or a Joint License.

What Will the Law Label Say?

URN

As long as the factory’s URN is not jointly held with another importer, you are allowed to print their URN with your own company’s name and address when you are registered properly as an Importer. Otherwise, you may use the Joint URN that is exclusive between the manufacturer and the I/W/D/R.

MADE FOR / IMPORTED BY / DISTRIBUTED BY

Importer’s Name

Importer’s Address

MADE IN

The country of origin should still list the manufacturing location’s country.

Who Is the Importer?

The term “importer” is any company that imports bedding or upholstered furniture products to be sold in the U.S. Typically this is an importer, wholesaler, distributor or retailer (I/W/D/R). 

If a company’s information (name/address) is printed on the label in lieu of the manufacturer’s information, they are then considered an “importer" and require registration.

What Is Importer Licensing?

As long as the manufacturer holds a Manufacturer License, the stuffed article can be legally sold in the United States. However, many importers prefer to list their own company information on the product’s law label. Obtaining an Importer License is the only way to do so. 

Benefits and Risks of Importer Licenses

Obtaining an Importer License allows you to list the importer’s name on the stuffed product’s law label. This gives importers the opportunity to build their brand and enhance name recognition in the stuffed articles industry.

Bear in mind that if your company’s name is printed on the law label, you may be responsible for any fines the product may incur from license or registration violations. If you need support staying compliant, our sister company GRS offers Monitored Services to help.

How Do I Get an Importer License?

There are eight (8) regulatory agencies that require importer licensing, but there are different requirements for each license. Some agencies issue “blanket” licenses while others issue URN-specific licenses:

• “Blanket” licenses — The importer only needs one license, no matter how many factories/URNs they work with.
• URN-specific licenses — The importer needs a license for each factory/URN they work with.

Our sister company GRS can help you determine which type of Importer Licensing you need, and assist with the registration process.

What Is Joint Licensing?

If you want to list the importer’s name and address on the stuffed product’s law label but you want more control over the registration process, you can choose a Joint License.

The term “joint” applies to an I/W/D/R that registers with a manufacturer to sell a specific stuffed product in the U.S. The two companies will apply together, or jointly, for the license.

Benefits and Risks of Joint Licenses

Joint Licenses offer I/W/D/Rs a level of control and oversight over registration, the license itself and renewals. This comes with three important benefits that give you peace of mind about your products:

1. The I/W/D/R’s name and address will be printed on the product’s law label.
2. The I/W/D/R will receive renewal notices, so you can ensure your manufacturer’s licenses are valid.
3. The joint URN is exclusive between the manufacturer and the I/W/D/R. The manufacturer cannot use that joint URN to make products for any other company to sell in the U.S.

There are no major risks associated with Joint Licenses as long as the I/W/D/R stays on top of renewals and other matters of ongoing compliance.

How Do I Get a Joint License?

In Joint Registration, the I/W/D/R will need to register together with the manufacturer. Our sister company GRS can help you apply together for a Joint URN in each of the three (3) U.S. states that offer Joint Registration. The licenses will be mailed directly to the I/W/D/R.

Get the Right Law Label & License

When you want to move forward with your law label, applying for the proper license is the first step. If you need support in getting your license, our sister company GRS is here to help. Set up a free consultation and the GRS team will be in touch.

Want to make sure your registration and law label are fully compliant? American Law Label offers label audits, where our team provides a comprehensive review of your label’s format, terminology, and registration with detailed feedback. The cost is $135 per label. Please use the button below to request an audit.

If you sell mattresses, you know how strict federal regulations can be around flammability. Here’s a quick refresher on 16 CFR 1633 flammability labels, and common mistakes that could make your mattress noncompliant.

What is a 16 CFR 1633 Label?

16 CFR 1633 labels are federal flammability labels for mattresses. They are mandatory for all mattresses, because the federal government requires every mattress to be put through a government-approved flammability test.

A 16 CFR 1633 label certifies that a mattress has passed flammability testing by an independent third-party laboratory.

Common Mistakes

Making these common errors can make your 16 CFR 1633 label noncompliant, and open you up to costly fines and violations.

• Wrong Formatting — Label formatting guidelines are strict, and require specific font sizes, text box sizes, and text justification.
• Missing Foundation Intention — You must disclose whether the mattress is intended to be used with, without, or both with and without a foundation. You must also provide a foundation ID if it is intended to be used with a foundation.
• Missing Model Number or Prototype ID — Many customers leave this information blank. You must list the Model Number or Prototype ID for your label to be compliant.
• Other Missing Information — Your 16 CFR 1633 label needs complete information, like the manufacturer’s name, even if it appears on another label. This is because law labels are regulated by the state, and 16 CFR 1633 labels are regulated at the federal government.

Get Support for 16 CFR 1633 Labels

Need help designing or printing a 16 CFR 1633 label? American Law Label has your back. We can even audit your existing label to make sure it’s fully compliant with all federal flammability laws.

Big Changes for Stuffed Toys in PA

Pennsylvania now allows stuffed toys to be made with recycled filling materials. The state will require these types of products to note the use of recycled materials on the label.

If the stuffed toy contains recycled materials, the label cannot state “All New Material.” Importantly, this contradicts the requirements of Ohio and Massachusetts which require that recycled material be called “All New Material” if undergoing melting and re-extrusion.

Originally Pennsylvania suggested a two-label solution, where a stuffed toy with recycled fill would have a PA-specific “Recycled" label with the PA URN as well as an OH/MA “All New Material" label with the OH/MA URN. However, we received word from Ohio that they will not accept this approach.

Thus, there is currently no way to label recycled materials that would allow one uniform law label in PA, OH, and MA. We are conferring with state officials and will reach out with details.

Company Updates

New ALL Website Design

Compliance isn’t always simple—but with our fresh website design, it’s simpler than ever to get peace of mind that your products are fully compliant. We hope you find it even easier to see your compliance status, understand your next steps, and get support from the ALL team.

Our Labeling Team Keeps Growing

We’re always looking for top talent to join our team of compliance experts. In 2024 we onboarded a new labeling design specialist to spearhead all label design for ALL and GRS customers. 

Webinars: Stay Ahead of the Curve

Want to get a crash course in compliance? The ALL/GRS team regularly hosts virtual events covering the hottest topics facing the industry, like:

• Law Labels and Registration 101
• Utah’s Online Visibility Requirements
• Canadian Labels

Grab your tickets to upcoming events, and subscribe to our calendar to stay informed about new learning opportunities.

Conference Recaps

The ALL/GRS team attended some great conferences and industry events throughout 2024! We put together some quick recaps in case you weren’t able to attend.

IABFLO International Annual Conference 2024

As long-time IABFLO partners, we were excited to give a presentation at this year’s conference on correcting non-compliant labels in the marketplace. Other topics of note included transitions to online licensing systems, recycled materials, and online law label requirements.

IABFLO RECAP

ICPHSO Annual Meeting and Training Symposium 2024

Our team’s participation at the ICPHSO 2024 conference encompassed exhibition, sponsorship, and presentation. In our “The Push and Pull of Sustainability" presentation, we explored the delicate balance between regulatory obligations and stakeholder expectations in achieving sustainability goals. 

ICPHSO + ICFA RECAP

JPMA Summit 2024

As relatively new members of Juvenile Products Manufacturers Association (JPMA), we were excited to attend the organization’s annual Summit for the first time. Highlights included tips on Truth in Advertising, legal best practices for manufacturers, and PFAS bans.

JPMA RECAP

ICFA Elevate 2024

The International Casual Furnishings Association (ICFA) conference provided our team with a unique perspective of the outdoor furnishings industry. One of the main issues discussed was the new and proposed rules regarding PFAS. 

ICFA RECAP

ISPA EXPO 2024

The International Sleep Products Association’s ISPA EXPO is the largest, most comprehensive, exhibition in the mattress industry. The ALL/GRS team was privileged to connect with the people, products, ideas, and opportunities that set the pace for the mattress industry’s future.

What to Know Heading into 2025

The law label industry is always moving and shaking! The ALL team put together these helpful guides to help you step confidently into 2025.

What Type of Label Does My Product Need?

In this guide we explore common labels that may be required in addition to law labels, and what types of products need them.

LABEL TYPE GUIDE 

Corrective Labeling: What to Do When Your Law Label Has a Mistake

Law label errors open you up to potential fines and violations, but you might not need an entirely new label! Read up on the benefits of corrective labeling.

CORRECTIVE LABELING GUIDE 

Law Label Materials: Why Do They Matter?

The material that your label is made of can spell the difference between compliance and costly fines. This guide covers common law label materials, the types of products they are useful for, and how American Law Label can support your label needs.

LAW LABEL MATERIAL GUIDE 

Approved Law Label Materials: Tyvek® vs. Tritext

Do you want to simply meet state requirements, or do you want to go above and beyond for consumers? Here we explore two popular law label materials accepted by states: Tyvek® and Tritext. 

TYVEK® VS. TRITEXT GUIDE

Tip-Over Safety Labels: Is Your Clothing Storage Product Compliant?

Each year, there is increased scrutiny for the manufacturers, importers and retailers of clothing storage units to protect children from the risk of tip-over. Here are the standards to be aware of.

TIP-OVER SAFETY LABEL GUIDE 

European Chemical Standards: What are ROHS and REACH?

If you sell stuffed articles in Europe, ROHS and REACH are two standards that will affect your products moving forward.

EU CHEMICAL STANDARD GUIDE

Stuffed Article Inspections

What do law label inspectors look for? In this third part of GRS’ three-part inspection guide, we cover the law label design violations that may get your product pulled from shelves.

LAW LABEL DESIGN VIOLATION GUIDE