Which US fire requirements apply to an upholstery job, and what you have to put on the label. Three questions.
Reupholstery is named in the standard — and there is an exception most people have never heard of. 16 CFR Part 1640 applies to furniture manufactured, imported or reupholstered on or after 25 June 2021. But CPSC confirmed to the National Upholstery Association that it does not apply where the piece keeps the same owner through the work. That single distinction decides most jobs, so it is the first question below.
Who owns the piece when it leaves your shop?
This is the question that decides most jobs, and the one almost nobody knows about. The National Upholstery Association asked CPSC directly, and the answer was that the standard does not apply where the furniture keeps the same owner through the work.
What is it?
The standard covers upholstered seating for indoor use.
What fire evidence do you have for the materials?
TB 117-2013 tests four component types separately: cover fabric, barrier material, resilient filling, and decking material where there is a loose cushion.
Sources. Everything above is taken from:
- 16 CFR Part 1640, Standard for the Flammability of Upholstered Furniture — eCFR
- California Technical Bulletin 117-2013 — Department of Consumer Affairs
- CPSC direct final rule, 9 April 2021 — Federal Register
- National Upholstery Association guidance for upholsterers, including their clarification from CPSC on reupholstery and change of ownership — NUA
This is informational guidance from a working upholsterer, not legal advice, and I work in Britain rather than the United States. State and municipal rules sit on top of the federal standard and differ. Where a job carries real risk, confirm the specification in writing with whoever is responsible for it, or ask the CPSC Small Business Ombudsman, who exists for exactly this.
Working in Britain instead? Use the UK fire regulations checker — the two regimes are genuinely different and the British one tests against an open flame as well as a cigarette.