California Law Label Requirements: Contents, Colors, and Penalties

California law label requirements apply to anyone who manufactures, imports, wholesales, or renovates upholstered furniture, bedding, or filling materials sold in the state. Every covered product must carry a Uniform Law Label that identifies the filling materials by generic name and weight, shows the manufacturer’s Bureau of Household Goods and Services (BHGS) registration number, uses the correct color code, meets minimum size and print specifications, and is attached where a buyer can see it. Upholstered furniture also needs a flammability label and a flame retardant disclosure, and secondhand or chemically flagged products carry additional labels on top of the law label.

Which Products Are Covered

The labeling mandate reaches any product containing concealed filling. That includes upholstered furniture such as sofas, chairs, cushions, hassocks, and headboards, and bedding such as mattresses, box springs, pillows, comforters, sleeping bags, mattress pads, and quilted bedspreads.¹ Bulk filling sold loose or pre-fabricated, like batting and stuffing, is covered too.²

Origin doesn’t matter. Goods made in California, brought in from another state, or imported from abroad all need a compliant label before they can be offered for sale.³

What the Label Must Say

Three categories of information belong on the law label: the filling, the manufacturer, and the product itself.

Filling materials are listed by generic name and physical form, in order of predominance by weight, largest component first. Brand names and trademarks don’t count as generic descriptions.⁴ Something like “shredded polyurethane foam” or “polyester fiber batting” is the required style, not a product line name. Each material’s percentage by weight has to be printed on the label.²

Plumage products have fixed thresholds. A product can only be labeled “down” if it contains at least 75% down and plumules. Products with 50% to 74% must be labeled “down and feathers.” Products with 5% to 49% must be labeled “feathers and down.”⁴ These distinctions are a common source of citations.

The label must also include the manufacturer’s name and the BHGS-issued registration number so the product can be traced to its source. Bedding items such as mattresses, comforters, sleeping bags, and pillows must show finished width and length in inches; decorator pillows are exempt from the size rule.¹

Color Coding: New, Used, and Owner’s Material

California uses three label colors so a consumer can tell at a glance what’s inside:

White label with black ink: new filling materials.
Red label with black ink: contains secondhand or used materials, in whole or in part.
Green label with black ink: “Owner’s Material,” meaning the customer supplied the filling.¹

Size, Print, and Durability

The label itself must measure at least 2 inches by 3 inches, and larger if the required text won’t fit at the minimum. All printing has to be in capital letters at least one-eighth of an inch tall, in English. The label material must be durable enough that it cannot be easily torn or defaced.¹

Where the Label Goes and Which Type to Use

The label has to be securely fastened to the finished product in an openly and easily visible spot. It cannot be concealed or obstructed in any manner.¹ Tucking a label inside a zippered compartment, hiding it under a cushion, or covering it with packaging all break the rule.

The format varies by product type. BHGS designates numbered label types:

Type No. 1: upholstered furniture without loose cushions, decorator pillows, and similar items.
Type No. 2: furniture with loose cushions.
Type No. 6: bed pillows, comforters, and mattress pads.
Type No. 7: sleeping bags, mattresses, and box springs.
Type No. 8: bulk filling material like batting.¹

Using the wrong label type is a citable violation.

One boundary worth stating: the familiar “do not remove” language is directed at manufacturers, distributors, and retailers. A consumer can remove the label after purchase without any legal consequence.

Flammability and Flame Retardant Labels on Upholstered Furniture

Upholstered furniture manufactured after January 1, 2015 must carry a separate flammability label confirming compliance with Technical Bulletin 117-2013. The wording is prescribed word for word: “This article meets the flammability requirements of California Bureau of Household Goods and Services Technical Bulletin 117-2013. Care should be exercised near open flame or with burning cigarettes.”⁵ Manufacturers that also meet the stricter TB 116 standard can state compliance with both bulletins on the same label.

Senate Bill 1019 adds a separate flame retardant disclosure. Upholstered furniture must carry a checkbox statement showing whether the upholstery materials contain added flame retardant chemicals, with the manufacturer marking the applicable box with an “X.” The disclosure must also state that California has determined its fire safety requirements can be met without adding flame retardant chemicals and that the state has identified many such chemicals as harmful to human health.⁶ Both the flammability label and the flame retardant disclosure have been mandatory since January 1, 2015.

Sanitization Labels for Secondhand Products

Products containing used filling face stricter rules. In addition to a red law label, a secondhand article that has been sanitized needs a separate sanitization label. That label must be printed on a yellow background with black ink, measure at least 3 inches by 3 inches, and certify that the product was sanitized through a process approved under the Home Furnishings and Thermal Insulation Act.⁴

Type sizes on the sanitization label are set. “Secondhand (used) article” and “sanitized” must appear in capital letters at least three-eighths of an inch tall. The “under penalty of law” statement must be in capitals at least one-eighth of an inch tall. The label must be made from erasure-proof paper of a grade that won’t change color when adhesive is applied, and it must be affixed with silicate of soda or another approved adhesive.⁴

California does not require a separate sterilization permit for animal-based fillings like feathers and down, though some other states do. If a manufacturer already holds an out-of-state sterilization permit number, the BHGS will allow it to appear on the plumage label.

Proposition 65 Warnings Are Separate

Proposition 65 warnings are not part of the law label, but they often apply to the same products. Warnings are required when a product exposes consumers to chemicals the state has identified as causing cancer or reproductive harm. For furniture and bedding, common triggers include formaldehyde, antimony trioxide, and chlorinated tris flame retardants.⁷

These warnings have their own formatting rules. They must be prominently displayed and conspicuous enough that an ordinary consumer would see, read, and understand them under typical purchase or use conditions. The triangular warning symbol must appear to the left of the warning text, sized no smaller than the height of the word “WARNING.” Short-form warnings placed directly on a product label must use at least 6-point font.⁸ The Prop 65 warning sits alongside the law label; it doesn’t replace it.

The BHGS Registration Number

The registration number printed on the law label comes from the BHGS, and no manufacturer, importer, wholesaler, or renovator can operate without a valid license or registration.³ Application and fees go to the BHGS, and processing typically runs four to six weeks depending on workload.⁹ Build that lead time in before a product launch.

Companies with more than one manufacturing location need a separate registration for each facility. Importers bringing in furniture or bedding made outside the United States must also be registered; the definition catches anyone who manufactures or wholesales, through employees or agents, covered articles produced abroad for sale in California.³

Uniform Registry Number for Multi-State Sellers

Manufacturers selling across multiple states can use the Uniform Registry Number (URN) system. Under it, a manufacturer registers in one state, then contacts other states where products will be sold and asks to be licensed under the same number. The URN on the law label carries a prefix identifying the issuing state, and a suffix in parentheses showing the actual state or country of manufacture when it differs.¹⁰ Confirm with the BHGS that a URN will be accepted, since each state keeps its own licensing rules.

Penalties for Getting the Label Wrong

BHGS inspectors visit manufacturing sites, warehouses, and retail stores to check labels and registration status. When they find violations, the bureau can issue warnings, impose fines, order recalls, or seize mislabeled goods.¹¹ Operating without a valid license or with expired registration exposes a business to all of those actions.

The California Attorney General can bring lawsuits under the Unfair Competition Law, which prohibits any unlawful, unfair, or fraudulent business act, and local district attorneys and city attorneys can prosecute violations as well.¹²

Private lawsuits are the other exposure. California’s Consumer Legal Remedies Act lets an individual consumer sue over deceptive practices, including misleading product labels. A CLRA plaintiff must show they purchased or sought to purchase the product for personal or household use, that the manufacturer engaged in a prohibited practice such as misrepresenting a product’s characteristics, that the consumer was harmed, and that the harm resulted from the manufacturer’s conduct.¹³ Where a misrepresentation is material, courts can infer that the consumer relied on it. A single wrong filling percentage or a missing flame retardant disclosure can seed class action litigation that costs far more than the label itself.

1
Legal Information Institute. Cal. Code Regs. Tit. 4, 1126 – Official Law Label Requirements
2
Cornell Law School. Cal. Code Regs. Tit. 4, 1125 – Labeling Requirements
3
Bureau of Household Goods and Services. State Licensing Requirements
4
Bureau of Household Goods and Services. Official Law Label Requirements for Upholstered Furniture and Bedding
5
Bureau of Household Goods and Services. FAQ for Technical Bulletin 117-2013
6
Bureau of Household Goods and Services. Industry Advisory – Senate Bill 1019 Upholstered Furniture Flame Retardant Chemicals
7
OEHHA. Furniture Products – Proposition 65 Warnings
8
OEHHA. Frequently Asked Questions for Businesses – Proposition 65 Warnings
9
Bureau of Household Goods and Services. Licensing Frequently Asked Questions – Home Furnishings and Thermal Insulation
10
Utah Department of Agriculture and Food. Uniform Registry Number
11
Legal Information Institute (LII) / Cornell Law School. Division 3 – Bureau of Household Goods and Services
12
California Legislative Information. California Business and Professions Code 17200
13
California Legislative Information. California Civil Code – Consumer Legal Remedies Act