California TB 117-2013

California Technical Bulletin 117-2013 (TB 117-2013), titled Requirements, Test Procedures and Apparatus for Testing the Smolder Resistance of Materials Used in Upholstered Furniture, is the primary flammability safety standard governing upholstered furniture sold across California and adopted throughout the broader United States. Administered by the Bureau of Household Goods and Services (BHGS), TB 117-2013 replaced the older 1975 open-flame standard with a focus on smolder resistance—evaluating how furniture cover fabrics, filling materials, and barrier layers withstand lit cigarette ignition sources.

Under federal legislation (the COVID-19 Regulatory Relief Act / SOAR Act), the US Consumer Product Safety Commission (CPSC) codified TB 117-2013 into mandatory federal law under 16 CFR Part 1640. Consequently, compliance with TB 117-2013 smolder test parameters and accompanying flame-retardant chemical disclosure labels is compulsory for all residential upholstered furniture distributed nationwide.

Material Test Sections and Smolder Evaluation Criteria

TB 117-2013 establishes standardized laboratory test methods using a simulated miniature bench assembly ignited by a lit standard cigarette:

Flame Retardant Chemical Mandates (SB 1019 & AB 2998)

TB 117-2013 was intentionally engineered to allow furniture components to achieve smolder resistance without requiring toxic chemical flame retardants:

• SB 1019 Label Disclosure: Mandates that all residential furniture carry a compliance law label explicitly stating whether chemical flame retardants were added above 1,000 ppm (0.1%).
• California AB 2998 Ban: Prohibits the manufacture, distribution, or sale of juvenile products, mattresses, and upholstered furniture containing halogenated, organophosphorus, or heavy metal flame-retardant chemicals at levels exceeding 1,000 ppm.
• Interference with Federal Safety: Importers must ensure furniture achieves smolder compliance through tight fabric weave density or inherent barrier linings rather than adding restricted chemical treatments.

Law Labels, SB 1019 Statement, and Traceability

Upholstered furniture items entering the US market must bear a compliant, permanently attached TB 117-2013 Compliance Label (often combined with Uniform Law Labels):

• Label Formatting Rules: Must feature bold headings (minimum 1/8-inch height), legible black text on white backing, and state the exact flame-retardant chemical inclusion status per SB 1019 mandates.

Practical Module: On-Site TB 117-2013 Verification & QC Practice

Quality control inspectors conducting Pre-Shipment Inspections (PSI) on upholstered furniture shipments must execute the following physical verification steps on the factory floor:

Step 1: Material Density and Cover Fabric Inspection

• Verify that production cover fabric weight (g/m²), weave density, and backing treatments match the tested material swatches listed in the laboratory test report.
• Check that flexible polyurethane foam fillings meet specified density (kg/m³) and indentation force deflection (IFD) parameters.

Step 2: Fire-Barrier Layer Integration Audit

• For items utilizing fire-barrier linings underneath non-compliant decorative outer fabrics, inspect internal seat cushions and armrests to ensure the barrier layer fully encapsulates the foam core without gaps.
• Verify that thread seams and piping details do not expose raw polyurethane filling to potential surface smoldering.

Step 3: Law Label Artwork & SB 1019 Statement Verification

• Inspect finished garments and upholstered pieces to confirm the TB 117-2013 compliance label is securely sewn into a visible seam (e.g., under the main seat cushion).
• Cross-check chemical test reports to verify that the "NO ADDED FLAME RETARDANT CHEMICALS" statement matches laboratory screening results.

Frequently Asked Questions (FAQ)

Q1: What is the primary difference between TB 117 (1975) and TB 117-2013?

TB 117 (1975) required filling materials to pass an open-flame test, which forced manufacturers to add heavy chemical flame retardants. TB 117-2013 focuses on smolder resistance against lit cigarettes, allowing furniture to comply using smolder-resistant cover fabrics or physical barriers without adding toxic chemicals.

Q2: Is TB 117-2013 mandatory across all US states or only in California?

Under 16 CFR Part 1640 (codified via the SOAR Act), CPSC adopted California TB 117-2013 as a mandatory national federal standard. Consequently, all residential upholstered furniture sold anywhere in the United States must comply with TB 117-2013.

Q3: Does TB 117-2013 apply to outdoor patio furniture?

TB 117-2013 applies specifically to residential indoor upholstered furniture. However, if outdoor furniture is marketed or suitable for indoor residential use, customs authorities and major retail buyers will enforce TB 117-2013 testing and labeling requirements.

Q4: How does a barrier material help a non-compliant cover fabric pass TB 117-2013?

If an outer decorative fabric fails Section 1 smolder testing, a fire-resistant barrier layer (Section 2) is inserted between the cover fabric and the inner foam. The barrier prevents smoldering heat from penetrating and igniting the underlying resilient foam core.

Q5: What are the risks of incorrectly marking the SB 1019 flame retardant disclosure check-box?

Mislabeling flame-retardant status constitutes a direct regulatory violation under California law and CPSC guidelines, leading to product holds, mandatory re-labeling fines, and potential enforcement actions under California AB 2998.

References

[1] California Bureau of Household Goods and Services. Technical Bulletin 117-2013: Requirements, Test Procedures and Apparatus for Testing the Smolder Resistance of Materials Used in Upholstered Furniture[S]. Sacramento: BHGS, 2023.

[2] US Consumer Product Safety Commission. 16 CFR Part 1640: Standard for the Flammability of Upholstered Furniture[S]. Washington D.C.: Federal Register, 2021.

[3] State of California Legislative Counsel. Senate Bill No. 1019 & Assembly Bill No. 2998: Upholstered Furniture Flame Retardant Chemicals[S]. Sacramento: California State Legislature.

Reference Notes

1. Technical Bulletin 117-2013 establishes standard test methods for evaluating smolder resistance in cover fabrics, barriers, and fillings.
2. 16 CFR Part 1640 adopts TB 117-2013 as a binding federal safety standard enforced across all US states by the CPSC.
3. California SB 1019 and AB 2998 govern mandatory flame-retardant chemical disclosures and restrict toxic chemical additives in consumer furniture.