Furniture vendor compliance checklist for 2026: STURDY, TB 117-2013, TSCA formaldehyde and CPSC eFiling
To supply U.S. furniture retailers, clothing storage units must meet the STURDY tip-over standard, upholstered furniture must meet TB 117-2013 and carry the label, composite wood must meet TSCA Title VI, and children's furniture needs third-party testing. Since July 8, 2026, importers eFile certificate data at entry, so who the importer is decides who files.
The U.S. has no single furniture certification. Mandatory standards depend on the product: tip-over for clothing storage units (16 CFR 1261), flammability for upholstery (16 CFR 1640), formaldehyde for composite wood (TSCA Title VI), flammability for mattresses (16 CFR 1632 and 1633), and third-party testing for children's furniture. Since July 8, 2026, importers must also eFile certificate data with Customs at entry. The importer of record files; the factory supplies the certificates and test data.
This is a framework checklist to help you line up with your testing lab, attorney and retailer. Whether a standard applies to a given product, and how to test it, is for a CPSC-accepted lab and an attorney to decide.
Dressers and chests: the STURDY tip-over standard
The 2022 STURDY Act directed CPSC to set a mandatory tip-over standard for clothing storage units. CPSC adopted ASTM F2057-23 as 16 CFR 1261 for units manufactured after September 1, 2023.
Scope: free-standing clothing storage units 27 inches or taller, such as chests, dressers, armoires and drawer units. Built-in units and certain other products are excluded.
Requirements: pass stability testing without the tip restraint installed, carry the required warning label, include a tip restraint, and issue a General Certificate of Conformity (GCC).
Upholstered furniture: TB 117-2013 and the label
A 2020 federal law made California's TB 117-2013 the national standard, and CPSC codified it at 16 CFR 1640, effective June 25, 2021. Upholstered furniture made, imported or reupholstered on or after June 25, 2022 also needs a compliance label stating it meets CPSC's upholstered furniture flammability requirements. Use the exact wording in the current text of 16 CFR 1640.4.
How to comply: the cover fabric and filling each pass smolder tests, or a passing barrier fully surrounds the filling.
Composite wood furniture: TSCA Title VI formaldehyde
Furniture made with MDF, particleboard or hardwood plywood must use panels that meet the emission limits in 40 CFR 770, certified by an EPA-recognized third-party certifier. Finished goods carry a TSCA Title VI compliant label, importers certify TSCA compliance at entry with the compliance noted on the invoice or bill of lading, and distributors and retailers keep records for 3 years.
Mattresses and children's furniture
Mattresses must pass the cigarette ignition test in 16 CFR 1632 and the open-flame test in 16 CFR 1633. Mattresses from several countries carry antidumping duties, so confirm origin before importing.
Children's furniture, including kids' beds and bunk beds, is a children's product: testing by a CPSC-accepted third-party lab, a Children's Product Certificate (CPC), tracking labels, and lead and surface coating limits, with bunk beds under their own standard at 16 CFR 1513.
Supply chain: UFLPA, the Lacey Act and California's Prop 65
Uyghur Forced Labor Prevention Act (UFLPA): goods with inputs from Xinjiang are presumed to be made with forced labor. CBP can detain them and the importer has to prove otherwise, so furniture factories need traceable sources for wood, fabric and foam.
Lacey Act: certain wood furniture tariff lines require a declaration of species and country of harvest at entry.
California Proposition 65: products sold into California need warnings for listed chemicals. Rooms To Go has no California stores, but the same item sold into California through other channels needs its own review.
What's new in 2026: CPSC eFiling
CPSC published a rule on January 8, 2025 amending 16 CFR 1110. Starting July 8, 2026, importers of products covered by CPSC rules must file certificate data (the elements of the GCC or CPC) with Customs through ACE at entry; for goods entering a foreign trade zone, the date is January 8, 2027. Before, certificates only had to be produced on request; now they're filed with every entry.
Who files under FOB and DDP: under FOB origin terms, the retailer files as importer of record, but the factory provides the certificate and test data, and missing data can hold goods at the port. Under DDP, the factory or its U.S. company is the importer and owns the filing, so settle the data flow with your customs broker.
How do you book compliance costs?
Testing, certification, factory audits and label design are generally deducted as current expenses. Tooling made for a specific product follows the asset rules for its useful life, or the inventory cost rules if it's part of production cost. Retailer chargebacks for compliance failures (wrong labels, delays from missing certificates) reduce revenue and should be tracked separately for disputes and reconciliation. Recall costs are booked as incurred, and insurance recoveries are income.
If a U.S. subsidiary is the importer, these costs belong on its books. If the parent pays them on the subsidiary's behalf, treat that as a related-party transaction and report it on Form 5472.
How we can help
For the vendor model at retailers like Rooms To Go, FOB vs. DDP, tariffs, entity choice and platform comparisons, see our Rooms To Go supplier guide. YCL handles the tax and accounting side: booking compliance costs, the tax consequences of who imports, and Form 1120 with Form 5472 and intercompany pricing for U.S. subsidiaries. Product compliance is for testing labs and attorneys, and we don't give compliance opinions. Start with a 15-minute free consultation, or reach us on WeChat at YCLUSA.
Sources
CPSC: Clothing Storage Units business guidance
Federal Register: Safety Standard for Clothing Storage Units (May 4, 2023)
Federal Register: Standard for the Flammability of Upholstered Furniture (April 9, 2021)
CPSC: Upholstered Furniture FAQ
eCFR: 40 CFR Part 770, Formaldehyde Standards for Composite Wood Products
CPSC: Rules Requiring a General Certificate of Conformity
Last checked: November 9, 2026
This article is general information, not legal, product compliance or tax advice. Ask a CPSC-accepted lab and an attorney whether a standard applies to your product and how to test it.
Questions this article answers
Which furniture has to meet the STURDY tip-over standard?
Free-standing clothing storage units 27 inches or taller, such as chests, dressers, armoires and drawer units, manufactured after September 1, 2023. Under 16 CFR 1261 (ASTM F2057-23) they must pass stability tests without the tip restraint, carry a warning label, include a tip restraint and have a General Certificate of Conformity.
Do upholstered sofas need a flammability compliance label?
Yes. 16 CFR 1640 adopts California TB 117-2013 and took effect June 25, 2021. Upholstered furniture made, imported or reupholstered on or after June 25, 2022 must carry a label stating it complies with CPSC's upholstered furniture flammability requirements, worded as in the current 16 CFR 1640.4.
When did CPSC eFiling start, and who files?
From July 8, 2026, the importer of record files certificate data through ACE at entry for products covered by CPSC rules; goods entering a foreign trade zone follow from January 8, 2027. Under FOB terms the retailer usually files with data from the factory; under DDP the factory or its U.S. company files.
Are furniture testing and certification costs deductible?
Generally yes, as current expenses. Product-specific tooling follows the asset or inventory cost rules, and retailer chargebacks for compliance failures reduce revenue. Costs a parent pays for its U.S. subsidiary are related-party transactions reported on Form 5472.
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