We sat down with Maggie Terry, president of Legal Label Inc., to get clarification on the law label requirements for padded and upholstered products in the USA and Canada and we’re sharing that information here.
A “law label” is a label that must be attached to products that have covered padding- including soft structured or otherwise padded baby carriers. This label outlines what the internal stuffing or padding is made of, where the product is produced, and the ‘URN’ or Uniform Registry Number. This URN is tied to the manufacturing location. For companies who produce in a factory setting, the URN is tied to the factory and for legal labeling purposes your company is the importer (and the factory is the manufacturer.) For companies who run their own sewing operations/sewing houses, the URN is tied to your own operations and you are the manufacturer.
In the USA, 31 states have law label requirements. 13 of those states require state licensing (14 states require licensing if you produce mattresses/crib mattresses.) There are 8 states with active inspection processes. The repercussions of not complying with law label requirements vary by state from warnings to potential fines. In Canada, Quebec has padded products registration and labeling requirements. Ontario and Manitoba used to have these requirements as well but have suspended their programs at this time.
The average cost for a manufacturer to register in the required states is about $3500 for first year registration, with fees lessening in subsequent years. Companies like Legal Label can assist with this process for a fee (around $1000 to $2000 depending on the year) which is immensely helpful when navigating this complicated process.
There are a number of consulting companies out there to help you navigate this process if this is a requirement for your business and you want to access assistance. Below is simply a short list:
BCIA membership helps your business with all aspects of carrier compliance through education, referrals to industry experts and in-house compliance assistance. Not a member yet? Come and join us today!