Hello & Welcome!
It’s Friday today and that can only mean one thing – it’s time for this week’s Reader’s Question post!
Today I’ll be answering an email sent in to me by Steven, who is looking to start an importing business, but needs some help. And that’s exactly what I’m here for – so let’s get to it!
Hi Andrew,
I don’t want to bother you with a lengthy email as I’m sure you’re incredibly busy but I wanted to ask just one question about something that I just cannot find the answer to…
I’m starting to import homeware goods like throws, rugs, furniture etc. and I’m concerned with laws governing the import of fabrics. I’ve heard there are laws stating textile goods have to comply with standards i.e. fire retardant materials etc. but I’m struggling to find any info on it and don’t want to get the goods to customs and be told I can’t have them or be told that I’m not able to sell them on my site. Have you had any experience in this kind of work Andrew and can you shed any light?
I also wanted to say a quick thank you for all of your business related help, out of all of the blogs, Facebook pages, and YouTube channels out there, I find your content has explained queries the most clearly and to the point. Coming from a haulage background into this world has seemed daunting for me if I’m honest but I’m gonna give it my best shot!
If you get a moment to reply to my email, that would be brilliant!
Thanks again mate!
Steven
Thanks for your email & question Steven. And thank you for your kind words – I obviously put a lot of time and effort into this blog but it’s all worth it if I can help people achieve their dreams and create their own online business, so I’m very happy to hear that it’s been helping you.
Moving on to your question and yes – you’re 100% right, there are laws in place regarding the fire safety of furniture and related goods that you, as an importer and seller of such goods, have to comply with.
Specifically, it is The Furniture and Furnishings (Fire Safety) Regulations 1988 that you have to comply with.
These Regulations are UK Law “designed to ensure that upholstery components and composites used for furniture supplied in the UK meet specified resistance levels and are suitably labelled” and they’re enforced by the Trading Standards Department.
These regulations were created because the number of fire-related deaths in the home had increased to more than 700 a year in the 1980s and it’s estimated to have saved nearly a thousand lives so please take this seriously! Failure to comply with these regulations is an offence under UK Law and pleading ignorance “is not accepted as a defence.”
And you’ll notice I mentioned in the home, as these regulations only cover domestic use products and DON’T apply to products used in work environments, such as offices, schools, hospitals, hotels, restaurants etc. – these are covered by the 2005 Regulatory Reform (Fire Safety) Order.
Okay so moving on to the regulations themselves and like all such legal documents they’re very lengthy and hard to understand! But in short, there are 6 main parts to the regulations:
1. Filling materials must meet specified ignition requirements.
2. Upholstery composites must be cigarette resistant.
3. Covers must be match resistant (with certain exceptions as outlined in Section 8.2 and Appendix A5).
4. A permanent label must be fitted to every item of new furniture (with the exception of mattresses and bed-bases).
5. A display label must be fitted to every item of new furniture at the point of sale (with the exception of mattresses, bed-bases, pillows, scatter cushions, seat pads, loose covers sold separately from the furniture and stretch covers).
6. The first supplier of domestic upholstered furniture in the UK must maintain records for five years to prove compliance..
The products covered by these regulations are broken down into 6 different groups (A-F) as below:
So you may notice that some products that you would expect to be included are missing from this list, such as sleeping bags, pillowcases, curtains and carpets.
Now Steven specifically mentioned rugs as one of the products he’s looking to sell, so you may be in luck there as carpets are not covered under these regulations (you do still have to comply with the General Product Safety Regulations!)
However, the products listed in those 6 groups need to adhere to the regulations and this includes the testing requirements!
This includes making sure that:
- Furniture is not supplied which contains foam fillings (block or crumb polyurethane or latex rubber) that do not meet the requirements outlined in Schedule 1 of the Regulations.
- Furniture is not supplied which contains non-foam fillings that do not meet the requirements outlined in Schedule 2 of the Regulations.
- Composite fillings consisting of more than one filling material comply either by each individual filling separately complying or by the total composite being tested. In either case, any foam incorporated in the composite must comply with Schedule 1 of the Regulations.
- Furniture is not supplied with upholstery composites that do not pass the cigarette test as outlined in Schedule 4 of the Regulations.
- Furniture is not supplied with permanent, loose or stretch covers which do not pass the match test as outlined in Schedule 5 of the Regulations
The Furniture Industry Research Association (or FIRA) for short have created a really useful table which illustrates exactly what testing needs to be carried out for specific products:
Now obviously these won’t make sense by themselves, and you need to refer to the actual regulations alongside these tables!
Next let’s take a look at the labelling requirements as set out by the regulations – starting with display labelling:
“Display labelling is required to indicate the ignition resistance of each item of furniture and needs to be attached to all new furniture at the point of sale, with the exception of mattresses, bed-bases, pillows, scatter cushions, seat pads, loose covers (sold separately from the furniture) and stretch covers.
Furniture sold as a collection of items, such as three piece suites or a set of dining chairs must carry the appropriate display label on each individual item.
In all cases the display label must be attached to the furniture in a prominent position so that the label will be clearly visible to a potential purchaser of the furniture and the wording on both sides can be read with reasonable ease.”
The display label should differ depending on the item and what testing it’s had. Once again the FIRA have created a table that illustrates this perfectly:
As well as the display label, there are also requirements for permanent labels:
“Permanent labelling on furniture is intended to assist enforcement officers and show compliance with the specific ignition requirements for covers and fillings.
The prime objective of the permanent label is for enforcement officers to examine a label on a piece of furniture and obtain relevant information which will enable them to find out and confirm that the materials used in the item do comply with the Regulations.
They will also be able to complete a cross check of the claims being made on the label with the manufacturer’s records. Permanent labels need to be carried on all items of furniture with the exception of mattresses divans and bedbases.”
There are two version of permanent label that you can choose from:
- A short label that gives only the minimum required information and nothing more.
- A full label that gives all information about the product.
For complete information of what needs to be included on the label – please take a look at Parts 2 and 3 of Schedule 7 of the regulations.
While the design of the label is left up to the manufacturer (so there’s no set template for you to use), there are specific formatting rules that you need to follow:
- All words and numbers on the permanent label must be in medium letters of at least 10 point in upper or lower case. The letters must be legible, in durable print, and appear on a label of sufficient colour contrast to enable them to be seen clearly.
- The label must be durable and securely attached to the furniture (i.e. cannot be removed without causing damage to the label or the product and must be able to withstand the normal wear and tear of everyday use and misuse.
- The permanent label has to be securely attached to the external surface of the item. Attachment of the permanent label to the underside of the item is also permissible.
- The Regulations state that a Batch/ID number should be provided on the permanent label ‘if any’ is applicable to the product. However it is recommended that for best practice purposes, products should be assigned Batch/ID numbers for traceability and, if there should be a problem, future product recalls.”
And here is a good example of a permanent label, for both the full information and minimum information versions (once again taken from FIRA’s excellent guide):
*Important – the responsibility for ensuring that the permanent label is on the final product lies with the first supplier of the product in the UK!!!
Now this is a similar concept to what we’ve seen with the skin care products and other importing regulations, where it’s the first importer who has the most responsibilities when it comes to compliance.
And that brings me perfectly on to the last part of the regulations that I want to cover – who do they apply to?
The quick answer is that these regulations apply to EVERYONE in the supply chain, right from the materials used in the manufacture of furniture, all the way to the retailer who sells it to consumers, and even those who offer post-sale services such as re-upholstery and re-covering.
Here is a full list of who these regulations apply to:
- Persons who supply furniture, furnishings or reupholstery services including:
- Manufacturers
- Retailers
- Importers
- Persons who supply filling materials and fabrics to the furniture industry or direct to consumers.
- Persons who supply re-upholstery and re-covering services.
- Persons who supply second-hand furniture in the course of business or trade (e.g. auctioneers, charities).
“The Regulations also apply to persons who hire out furniture in the course of a business. This embraces furniture included in accommodation let in the course of business, such as holiday homes and residential furnished lettings (including houses, flats and bed-sits). As such, the Regulations apply to landlords, estate agents and letting agents).”
Basically anybody even close to the production and supply of furniture to consumers must adhere to these regulations.
BUT as I mentioned above, the main responsibility lies with the first supplier – known as the person responsible.
Once again FIRA have come to the rescue with a simple flowchart you can use to find out who is the first supplier in the UK:
And there you have it!
Sorry Steven if you were hoping for a quick and easy answer, as unfortunately furniture is just one of those industries where there is a lot of arduous extra work and regulations involved – if you do things properly.
And before anyone asks – yes I know there are furniture sellers on eBay who don’t follow these rules. There are always people who break the rules and that really doesn’t mean anything to you and me – people looking to create a real, stable, and dependable online business 😉
So I hope you’ve found this post useful. A special thanks goes to FIRA as nearly all the information from this article was from their excellent guide, which really perfectly breaks down the complicated regulations. You can download it yourself from the FIRA website, if you’d like even more info.
If you have a question or topic that you’d like my help with, then don’t hesitate – send it to my help desk here and it might be chosen for a future Reader’s Question post. Even if it’s not, you’ll still get a personal reply from me, within 24 hours, Mon-Fri!
Have a great weekend everyone!
Andrew
