Does Leather Upholstery Need TB 117-2013 Testing for the US?
Updated: 24 hours ago
Yes. TB 117-2013 applies to leather upholstery on seating sold in the US: as of October 2026 it is the federal flammability standard (16 CFR 1640), and leather covers are not exempt. California's regulator says leather resists smoldering and will most likely pass, but it must still meet the Section 1 cover fabric test.
Key Takeaways
The US CPSC adopted TB 117-2013 as the federal standard 16 CFR 1640, effective 25 June 2021.
It covers indoor seating with an upholstered seat, back or arm, including children's furniture; mattresses, bedding and exercise furniture are excluded.
Leather will most likely pass the smolder test, but it is not exempt from the Section 1 cover fabric test.
A cover that is untested or fails needs a Section 2 barrier, with the filling fully encased.
Finished furniture needs a permanent label: "Complies with U.S. CPSC requirements for upholstered furniture flammability".
TB 117-2013 and Leather Upholstery: The Detailed Answer
The US Consumer Product Safety Commission adopted California Technical Bulletin 117-2013 as a federal standard, 16 CFR part 1640, effective 25 June 2021. It covers indoor seating with an upholstered seat, back or arm that is manufactured, imported or reupholstered on or after that date, including furniture for children; mattresses, bedding and exercise furniture are excluded (Federal Register, 9 April 2021).
The test is a smolder test, not an open-flame test. For leather, the key guidance comes from California's Bureau of Household Goods and Services: leather "will most likely pass any smoldering test", but that "does not exempt leather cover fabrics" from Section 1. Testing is at the manufacturer's or supplier's discretion, as long as they can show the material meets the standard (BHGS TB 117-2013 FAQ).
What applies | What the rule says | What to ask your leather supplier |
|---|---|---|
Leather cover | Must meet TB 117-2013 Section 1, the cover fabric smolder test | A Section 1 lab report on the exact leather article, finish and colour you approved |
Untested or failing cover | A Section 2 barrier is required, with the filling fully encased | Test the leather early so the design does not need a barrier |
Label | Permanent label: "Complies with U.S. CPSC requirements for upholstered furniture flammability" | Agree in the PO who applies it to the finished piece |
Responsibility | Mainly the furniture manufacturer; importers and retailers must also ensure compliance | Keep test reports on file for each leather article |
On timing, send swatches of the approved leather to an accredited lab once the article, colour and finish are fixed and before bulk cutting. If you later change the tannage, finish or supplier, ask the lab whether the existing report still covers the new material.
Sanwas International is an LWG-certified OEM and private label leather manufacturer based in Jalandhar, Punjab, India, producing footwear, outerwear, furniture leather and hides for brands in India and worldwide. We supply furniture leather and leather hides to furniture makers, contract buyers and importers in India and abroad, including North America. We are LWG certified, offer first samples, run sampling from 72 hours and bulk from around 30 days, and check orders with AQL inspection. See our leather hides supply and sourcing page, read our upholstery leather spec guide for furniture makers, or talk to our team about your US furniture programme.
Frequently Asked Questions
Who applies the CPSC flammability label on leather furniture made in India?
The label goes on the finished piece of furniture, not on the leather hide, and it must be permanent. Federal rules treat the label as the manufacturer's certification of compliance, so if the furniture is made in India, agree in your purchase order that the factory applies it before shipping. US importers and retailers still share responsibility for selling compliant products.
Does TB 117-2013 apply to children's and outdoor leather seating?
Under 16 CFR 1640, upholstered furniture intended for children is included. The standard is defined around seating intended for indoor use, so outdoor-only furniture falls outside that definition. Confirm borderline products, such as indoor-outdoor pieces, with your testing lab or compliance adviser.
Does a TB 117-2013 report satisfy UK hotel buyers?
No. UK contract upholstery is normally specified to BS 7176, which tests the finished cover-and-filling combination against match, cigarette and crib 5 ignition sources. If you sell the same leather into both markets, plan for separate tests.
Quote Leather for Your US Furniture Programme
US furniture makers, contract buyers and importers: share the leather type and finish, colours, quantity in hides or square feet, destination city or port, preferred Incoterm and target delivery date. Ask for swatches so you can test them before you commit.
Include these details in your enquiry:
Product category and style (footwear, jacket, upholstery leather, hides or crust)
Leather type, finish and colour
Target quantity per style and colour
Delivery city in India or destination country, plus preferred Incoterm
Target delivery date and whether you need a sample before bulk
Contact Sanwas International
Mob: +91 8728858686
Address: 308 Leather Complex, Kapurthala Road, Jalandhar, Punjab 144002, India
Comments