United States furniture compliance: what to check before a quote
A product report has to match the exact model and construction. These are the main evidence routes for commercial seating and composite-wood furniture in a US project.
Start with the product, not a certificate list
The destination specification decides what applies. The checks below are not a complete legal list; they show why an office chair report, an upholstery label and a composite-wood declaration answer different questions.
1. General-purpose office chairs — ANSI/BIFMA X5.1
BIFMA lists ANSI/BIFMA X5.1-2017(R2022) for general-purpose office chairs. Its scope includes general office and institutional seating, side and guest chairs, stacking chairs, tablet-arm chairs and stools. Ask for the complete report, exact model and construction. BIFMA also lists separate standards for large-occupant, public and lounge, and educational seating, so do not use X5.1 as a universal chair report.
2. Indoor upholstered seating — 16 CFR Part 1640
CPSC states that Part 1640 applies to indoor seating with an upholstered seat, back or arm and requires a permanent label reading “Complies with U.S. CPSC requirements for upholstered furniture flammability.” Match the cover, barrier, filling and decking in the product to the construction behind the evidence.
3. Composite wood — TSCA Title VI
EPA states that hardwood plywood, medium-density fibreboard and particleboard, and finished goods containing them, are covered by the rule. Finished goods or their boxes or bundles require the TSCA Title VI compliance label, subject to the rule. Ask which board sits in each chair, table, storage unit or casegood and keep the supporting supplier records with the item.
Also check — the US antidumping order on wooden bedroom furniture (A-570-890)
Separately from product evidence, the US Department of Commerce has an antidumping duty order on wooden bedroom furniture from China, case A-570-890. Its continuation notice of 14 September 2022 (87 FR 56397) describes the merchandise as made substantially of wood products and lists items such as wooden beds, headboards, night tables, dressers, chests and wardrobes. It excludes seating furniture, mattresses, office furniture, dining room furniture and other non-bedroom furniture. Read hotel guestroom casegoods line by line against the scope text, and ask your customs broker to confirm the position before you order. FBM Sourcing’s reading guide to the order sets out the record. For Canada, see Canada compliance.
Also check — tariff classification under HTS Chapter 94
Separately from product evidence, every line of a furniture order is classified under the Harmonized Tariff Schedule of the United States (HTSUS). Classification is decided by the importer and its customs broker; we list the Chapter 94 headings here as a starting point and do not state duty rates.
- 9401 — seats (other than those of heading 9402), whether or not convertible into beds, and parts.
- 9402 — medical, surgical, dental or veterinary furniture, and barbers’ and similar chairs having rotating as well as both reclining and elevating movements, and parts.
- 9403 — other furniture and parts, divided by material and, for wooden furniture, by the kind of room it is used in.
- 9404 — mattress supports and articles of bedding and similar furnishing, such as mattresses, cushions and pillows.
- 9405 and 9406 — luminaires and illuminated signs not elsewhere specified, and prefabricated buildings.
Note 2 to the chapter classifies articles in headings 9401 to 9403 only if they are designed for placing on the floor or ground, but keeps cupboards, bookcases, other shelved furniture and unit furniture, and seats and beds, in those headings even if they are hung or fixed to the wall. Read from HTS Revision 21 (2026) on 16 October 2026. Our article HS Chapter 94 for contract furniture reads the headings and notes in full.
Also check — Importer Security Filing for the container
Separately from product evidence, a container that arrives in the United States by vessel is covered by the Importer Security Filing rules in 19 CFR Part 149. The rule names the ISF Importer, lists ten data elements and sets time points, the first of which is 24 hours before the cargo is laden aboard the vessel at the foreign port. Which party files is for your importer and customs broker to settle. Our article Importer Security Filing for a contract furniture container reads the text of Part 149.
Also check — accessibility standards for the facility
Separately from the product, accessibility requirements for a facility in the United States are written in the 2010 ADA Standards for Accessible Design. They set out how many dining surfaces and counters must be accessible and how the accessible portion is measured. Whether they apply to your project, and which edition, is for your project designer. Our articles on accessible dining surfaces and reception and service counters read the relevant sections.
What to request from a furniture source
Put the document beside the item number in the schedule. A certificate for a company is not proof for every model.
For chairs
- Exact model and configuration in the complete report.
- Standard and edition, test laboratory and report date.
- Drawing comparison for base, mechanism, arms, back and seat.
- Separate route if the chair is for a large occupant, a public lounge or education.
For upholstery
- Cover, filling, barrier and decking specification.
- Permanent Part 1640 label where the federal rule applies.
- Any state, local, operator or project fire requirement selected by the project team.
For composite wood
- Panel type and supplier by item.
- TSCA Title VI statement and finished-good label.
- Records linking the panels and finished goods to the source.
United States compliance: questions project teams ask
Does ANSI/BIFMA X5.1 cover every chair?
No. BIFMA lists separate standards for public and lounge seating, large-occupant seating and educational seating. Select the standard from the product and project specification.
Is a BIFMA logo enough?
No. Ask for the complete report and verify the model and construction against the quoted drawing. If a BIFMA Compliant listing is claimed, verify that listing separately.
What does Part 1640 cover?
CPSC describes it as the federal flammability rule for indoor upholstered seating with an upholstered seat, back or arm. It also requires a permanent compliance label.
Which wood products are in TSCA Title VI?
EPA identifies hardwood plywood, MDF, including thin MDF, and particleboard, plus finished goods containing those products.
Does FBM Furniture decide the law for the project?
No. Your specifier, importer and approving authority decide what applies. Tell us the destination and specification, and we check the product evidence before we quote.
Send the destination specification with the schedule
We check the exact model, report and material evidence before we quote.