California Rules for Contract Upholstered Seating: TB 133, TB 117-2013, the 1,000 ppm Flame Retardant Limit and the 2027 Textile Fiberglass Ban
TB 133, TB 117-2013, the 1,000 ppm limit and the 2027 fiberglass ban, read from the Bureau’s law book and FAQ
A hotel, a care home or a restaurant that buys upholstered seating for a California project is buying against more than one rule. Specifications still cite “TB 133” for seating in public buildings, while the Bureau that wrote it says it has been repealed; the baseline for filling materials and cover fabrics is Technical Bulletin 117-2013; a 1,000 parts per million limit on flame retardant chemicals has applied since 2020; and a ban on textile fiberglass in upholstered furniture is printed with a start date of 1 January 2027.
This article reads the California Bureau of Household Goods and Services’ Home Furnishings and Thermal Insulation Act Rules and Regulations, 2026 Edition, which holds the Business and Professions Code provisions and Title 4 of the California Code of Regulations. We downloaded it on 25 October 2026; the file name of the PDF indicates an effective date of 1 January 2026. We also read the Bureau’s AB 2998 FAQs, October 2019 update and the cover and scope of Technical Bulletin 133. FBM Furniture works with companies only: Developers · General Contractors · Builders · Commercial Project Owners · Interior Design & Construction Companies · FF&E Solution Providers. It sets out what these texts say and does not decide whether any product complies. We did not read Technical Bulletin 117-2013 itself or its test details, the State Fire Marshal’s or any local fire code, Proposition 65, or any change to these provisions made after the 2026 Edition; your counsel or the Bureau confirms what applies to the project. Our general note on US furniture compliance places this alongside the federal rules.
Technical Bulletin 133: what it was and what the Bureau says now
The document is the Bureau of Home Furnishings and Thermal Insulation’s Technical Bulletin 133, dated January 1991, titled “Flammability Test Procedure for Seating Furniture for Use in Public Occupancies”. Its scope says the procedure is designed to test seating furniture for use in occupancies identified as or considered to be public occupancies, and that such facilities “might include, but are not limited to, jails, prisons, nursing care homes, health care facilities, public auditoriums, hotels and motels”. It adds: “This test procedure is not intended to be used for the evaluation of residential furniture.” The test facility it describes is a burn room 12 by 10 feet with an 8-foot ceiling, instrumented to monitor temperature, carbon monoxide concentration, smoke opacity and sample weight loss.
On its status, the Bureau’s AB 2998 FAQ is direct. Question 12 answers: “TB 133, the flammability standard for upholstered furniture in public occupancies, was repealed effective January 22, 2019. All upholstered and reupholstered furniture must now meet TB 117-2013.” Question 11 adds that the repeal “renders any exemption for products subject to TB 133 ineffectual”. The FAQ is dated October 2019, so it records the position at that date.
The 2026 law book is consistent with that. The name “Technical Bulletin 133” appears in it twice, both times in section 19100, the definitions for the flame retardant article: juvenile products do not include “products required to meet state flammability standards in Technical Bulletin 133”, and reupholstered furniture “shall not include products required to meet Technical Bulletin 133”. We found no section of the law book that requires a product to be tested to TB 133. A specification that still calls for TB 133 on a California project therefore needs a source for it, and the source cannot be the Bureau’s own regulations as printed in the 2026 Edition.
Technical Bulletin 117-2013 as the baseline: section 1374
Section 1374(a) of Title 4 of the California Code of Regulations sets the baseline. On and after January 1, 2015, “all filling materials and cover fabrics contained in any article of upholstered furniture and added to reupholstered furniture shall meet the fire retardant requirements” of Technical Bulletin 117-2013, which the section describes as dated January 2019, and be labeled in accordance with section 1374.3. The section does not apply to filling materials and cover fabric manufactured before January 1, 2015. Paragraph (b) adds that finished articles of upholstered furniture “may also be tested” to Technical Bulletin 116, and paragraph (c) says the requirements are flammability performance standards, testing under them being at the discretion of the licensee, while products and materials offered for sale in the state “shall meet all applicable flammability requirements”.
Section 1374.3 sets the label. An article that meets section 1374(a) but may not meet 1374(b) carries a permanently attached notice, in plain view, stating that it meets the flammability requirements of Technical Bulletin 117-2013, and an article that meets both carries a notice naming Technical Bulletins 116 and 117-2013. The label is at least 2 by 3 inches, the type at least one-eighth inch high and in capital letters, and it also has to comply with the general labeling requirements in sections 1126(a) and (b).
Section 1374.2 lists exemptions from the flammability requirement: cushions and pads intended solely for outdoor use; any article that is smooth surfaced and contains no more than one-half inch of filling material, provided it does not have a horizontal surface meeting a vertical surface; certain infant and juvenile items; and articles made to a written prescription for a named individual. The section applies to articles “other than furniture used for and in facilities designed for the care or treatment of humans”, so the exemptions are not available for furniture in care and treatment facilities. The FAQ adds that cushions and pads intended solely for outdoor use are exempt from TB 117-2013 and that, as a result, AB 2998 does not apply to them either.
The flame retardant chemical statement and the 1,000 ppm limit
Two separate provisions deal with flame retardant chemicals, and the Bureau’s FAQ distinguishes them. Section 19094, from SB 1019, is a labeling rule: the manufacturer of a covered product indicates on the label whether or not it contains added flame retardant chemicals, by marking one of two statements, “contain added flame-retardant chemicals” or “contain NO added flame-retardant chemicals”, followed by a notice about the state’s updated flammability standard. “Added” has a number: flame retardant chemicals present in a covered product or a component of it at levels above 1,000 parts per million (section 19094(a)(6)). Mislabeling can lead to fines against the manufacturers of the covered product and the component manufacturers, held jointly and severally liable (section 19094(c)(3)(A)).
Section 19101, from AB 2998, is a sales prohibition. On or after January 1, 2020, a person, including a manufacturer, “shall not sell or distribute in commerce in this state any new, not previously owned juvenile products, mattresses, or upholstered furniture that contains, or a constituent component of which contains, covered flame retardant chemicals at levels above 1,000 parts per million”. A covered flame retardant chemical is one with a functional use of resisting or inhibiting the spread of fire (or acting as a synergist to such chemicals) that is also a halogenated, organophosphorus, organonitrogen or nanoscale chemical, a “designated chemical” under the Health and Safety Code, or a chemical on the Washington State list of Chemicals of High Concern to Children identified as a flame retardant or synergist (section 19100(c)). Section 19101(c) carves out electronic components and their casings, components of upholstered furniture other than those named in section 19094(a)(1) (cover fabrics, barrier materials, resilient filling materials and decking materials), and certain fibers.
The FAQ states the difference in one answer: SB 1019 requires a label indicating whether flame retardant chemicals were added, while AB 2998 prohibits the sale and distribution of products containing them above 1,000 ppm, and “because the violation of AB 2998 resides in the sale or distribution, additional labeling and documentation is not required”. It also says AB 2998 did not amend or repeal SB 1019, so the label and documentation requirements remain. On public occupancies, Question 12 states that furniture intended for use in public occupancies “is also subject to AB 2998”.
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From 1 January 2027: textile fiberglass
Section 19101.5 in the 2026 Edition is a second prohibition with a start date still ahead. “On and after January 1, 2027, a person, including, but not limited to, a manufacturer, retailer, importer, or online seller, shall not manufacture, sell, offer, or distribute in commerce in this state any new, not previously owned juvenile product, mattress, or upholstered furniture that contains, or a constituent component of which contains, textile fiberglass.” A custom upholsterer is barred from using a replacement component that contains textile fiberglass from the same date.
The section defines the term: “textile fiberglass” means textile yarns whose composition includes one or more continuous glass filaments in a form suitable for knitting, weaving, or otherwise intertwining to form a textile fabric. It excludes thread or fiber used to stitch mattress components together, and yarns in which the glass filaments are corespun or sheathed by another fiber. The section names importers and online sellers, so it is aimed at the party that brings the finished product to a California buyer as well as at the maker. For a contract seating order, the text turns into a question for the factory: whether any cover fabric, barrier material, filling or decking in the item contains yarns with continuous glass filaments, and the evidence behind the answer.
Who is responsible, and what the text says about penalties
The responsibility provisions reach past the maker. Section 19072 states that “responsibility for compliance with this chapter rests not only with the manufacturer but also with the importer, wholesaler, retailer, or any person having in his or her possession any article of upholstered furniture or bedding, or filling materials with intent to resell contrary to the provisions of this chapter”. Section 19072.5 states that “importers, wholesalers, and retailers shall not sell or resell in California unlabeled upholstered furniture or bedding”, and that they shall obtain labels from the manufacturer and affix them before offering the furniture for sale. The FAQ, on who is responsible for AB 2998, says that for enforcement purposes responsibility may lie with the manufacturer, importer, wholesaler, retailer, or all parties in the chain of distribution.
The statute also defines the importer and licenses it. Section 19011.1 defines an importer as “a person who manufactures or wholesales, through employees or agents, any article of upholstered furniture, bedding, or filling material manufactured outside of the United States for the purpose of sale or resale in California”, and section 19053.1 says that “every importer shall hold an importer’s license”. Whether a contractor, designer or owner that buys seating for one project falls within that definition is not answered in the sections we read. Section 19051 exempts from the retail furniture dealer’s license a person whose sole business is designing and specifying for interior spaces and who purchases specific upholstered furniture items on behalf of a client from an appropriately licensed importer, wholesaler or retailer; that exemption is written for the retail license and does not mention the importer’s license. Counsel or the Bureau is the place to settle the point.
Fines for violations of sections 19101 and 19101.5 are set in section 19103(c): not less than 1,000 dollars and not more than 2,500 dollars for a first violation; 2,500 to 5,000 dollars for a second; 5,000 to 7,500 dollars for a third; and 7,500 to 10,000 dollars for any later violation, adjusted for inflation every five years under section 19103(e), so the figures in force may differ from the printed ones. The Bureau considers the nature and severity of the violation, good or bad faith, history, willfulness and cooperation. Where a person continues to sell products of the same stock keeping unit as products found non-compliant, after notice is posted on the Bureau’s website, fines may be assessed for the continued sale (section 19103(b)(2)(B)).
What to ask a seating supplier to put in writing
The texts turn into a short list of documents to request before a California order is placed. Each item maps to a provision above.
- The flammability label as it will appear on the finished item, with the section 1374.3 notice and, for covered products, the flame retardant chemical statement under section 19094. (CCR 1374.3; B&P 19094(b))
- The evidence that the filling materials and cover fabrics meet Technical Bulletin 117-2013, naming the materials. (CCR 1374(a))
- For every component named in section 19094(a)(1), a statement of whether covered flame retardant chemicals are present above 1,000 ppm, and the test evidence behind it. (B&P 19101(a); 19100(c))
- A written statement, for deliveries on or after 1 January 2027, on whether any cover fabric, barrier material, filling or decking contains textile fiberglass as the section defines it. (B&P 19101.5)
- Who the importer, wholesaler or retailer of record is for the California sale, and whether that party holds the license the statute requires. (B&P 19053.1, 19072, 19072.5)
- For any specification that cites TB 133, the document that requires it for this project, so that the requirement can be traced to a current source.
Send the schedule and the project location together, so that the package is quoted against the market it will be delivered into. For how FBM Furniture works with FF&E contractors, see our page for FF&E contractors.
Frequently asked questions
Is California TB 133 still required for hotel and contract seating?
The Bureau’s October 2019 AB 2998 FAQ states that TB 133, the flammability standard for upholstered furniture in public occupancies, was repealed effective January 22, 2019, and that all upholstered and reupholstered furniture must now meet TB 117-2013. The 2026 law book names TB 133 only in two definitions in section 19100 and does not require TB 133 testing in the sections we read. We did not read fire marshal or local fire codes, which can set separate requirements.
What is the difference between TB 117-2013 and TB 133?
Section 1374 of Title 4 requires the filling materials and cover fabrics of upholstered furniture to meet Technical Bulletin 117-2013 and to be labeled under section 1374.3. TB 133, dated January 1991, was a test procedure for seating furniture for use in public occupancies, including hotels and motels, and the Bureau states it was repealed effective January 22, 2019.
What is the California flame retardant limit for upholstered furniture?
Section 19101 prohibits selling or distributing new upholstered furniture that contains, or has a constituent component containing, covered flame retardant chemicals at levels above 1,000 parts per million, on or after January 1, 2020. Section 19094 separately requires a label statement saying whether the product contains added flame retardant chemicals, where added means above 1,000 ppm.
Does the California flame retardant limit apply to furniture for public occupancies?
Yes. Question 12 of the Bureau’s AB 2998 FAQ states that because the law applies to products required to meet TB 117-2013, upholstered and reupholstered furniture intended for use in public occupancies is also subject to AB 2998.
What changes on 1 January 2027?
Section 19101.5, as printed in the 2026 Edition, prohibits on and after January 1, 2027 the manufacture, sale, offer or distribution in California of new upholstered furniture that contains, or a constituent component of which contains, textile fiberglass, and bars custom upholsterers from using replacement components that contain it. Check the current text of the section before relying on the date.
Are importers responsible under the California home furnishings rules?
Section 19072 states that responsibility for compliance rests not only with the manufacturer but also with the importer, wholesaler, retailer or any person having the article with intent to resell contrary to the chapter, and section 19072.5 bars importers, wholesalers and retailers from selling or reselling unlabeled upholstered furniture in California. Section 19053.1 requires every importer to hold an importer’s license.
How does FBM Furniture support a contract seating package?
We review the brief, collect comparable quotations and manage the package for the project. For suppliers you nominate, we charge a 5% commission; for products we source for you, we quote a direct price. Our own team performs one inspection after bulk production is complete and before shipment, and your team is welcome to attend.
Planning a contract seating package for a California project?
Send your furniture schedule and the project location. Our team will review them and get back to you.