TB 117, CARB, flammability, and tip-over safety for retail furniture
Furniture compliance isn't a single standard — it's a web of overlapping regulations covering flammability, formaldehyde emissions, tip-over safety, and structural integrity. California Technical Bulletin 117-2013 (TB 117) is the critical benchmark for upholstered furniture flammability, and many large retailers now enforce it nationally, not just for California sales.
CARB Phase 2 formaldehyde emissions standards for composite wood products — plywood, particleboard, MDF — have become a major retailer requirement across the board. Costco is particularly strict about CARB compliance and may conduct independent testing on received furniture. Tip-over safety requirements under ASTM F2057 apply specifically to dressers and chests, and both retailers and the CPSC enforce them.
California Upholstered Furniture Flammability
Requires small-scale open flame testing (smoldering ignition) and a full-scale burner test. Upholstered fabrics and composites must resist both ignition and flame spread. Major retailers use this standard nationally — not just in California.
Composite Wood Formaldehyde Limits
Sets limits on formaldehyde emissions from plywood, particleboard, MDF, and hardwood plywood. The limits are 0.09 ppm for plywood and veneered panels, and 0.13 ppm for particleboard. Testing is conducted per ASTM E1333-16, the 24-hour test chamber method.
Federal Formaldehyde Standard
This is the federal baseline for composite wood products. CARB Phase 2 is more stringent and supersedes TSCA Title VI for suppliers selling nationwide. If you're meeting CARB Phase 2, you're already covered for TSCA Title VI.
Tip-Over Safety
Applies to chests, dressers, nightstands, and similar tall, narrow furniture. Products are tested for stability when a drawer or door is fully extended. Required for children's furniture and some adult categories as well.
California Low-Emissions Standards
An additional California regulation that limits VOC emissions from composite wood and finishes. Requires SCAQMD Rule 1113 compliance testing for finishing materials.
Painted Wood Furniture
Any furniture with painted surfaces needs all paints and stains tested for lead at under 90 ppm. This is especially important for vintage-style or hand-painted pieces.
| Requirement | Amazon | Walmart | Costco |
|---|---|---|---|
| TB 117-2013 (Upholstery) | Required | Required | Required |
| CARB Phase 2 (Wood) | Strongly recommended | Required for compliance | Strictly enforced |
| Tip-Over Safety (ASTM F2057) | If applicable to the category | If applicable | Required for dressers |
| Lead Paint Testing | Required | Required | Required |
| Test Report on File | For audit | Supplier documentation | May conduct re-testing |
| SVOC (Volatile) Testing | As applicable | Increasing requirement | Required for finishes |
Amazon requires TB 117-2013 certification for all upholstered furniture. Composite wood products need CARB Phase 2 documentation, and lead paint testing is required for all painted surfaces. Tip-over safety testing applies to dressers and tall, narrow storage furniture. Product detail pages should clearly state every certification the product holds.
Costco takes CARB compliance and formaldehyde emissions more seriously than almost any other retailer — they conduct independent testing on received furniture and will delist products that don't pass. Walmart requires SMETA audits of furniture suppliers. Both retailers enforce TB 117-2013 for upholstered items and lead paint testing for all painted products. If you're targeting Costco, plan for the highest compliance bar in the furniture category.
This is the leading cause of furniture failures. Composite wood materials — plywood, MDF, particleboard — from suppliers that don't meet CARB Phase 2 limits are a persistent problem. Even when suppliers claim compliance, independent testing often reveals failures. Costco conducts routine testing and will remove non-compliant products without warning.
Upholstered furniture that fails flame-spread or smoldering tests is a common issue. Testing requires both small-scale smoldering ignition tests and full-scale burner tests. Crucially, the testing needs to be done on the finished product — fabric, padding, and barriers together — not on raw fabric alone.
Dressers, chests, nightstands, and tall storage units need to pass ASTM F2057 tip-over testing. Products are evaluated with fully extended drawers to confirm they stay stable. Missing this certification creates real liability and leads to delisting.
Hand-finished or vintage-style furniture is a frequent source of lead paint violations. All painted surfaces need testing at under 90 ppm — including small decorative painted elements, especially on children's furniture or any piece where lead is a reasonable concern.
Using composite wood suppliers without CARB Phase 2 certificates is a straightforward compliance gap. Supplier documentation needs to include test reports from accredited labs. Using non-certified plywood or MDF directly violates both CARB and TSCA Title VI.
Using flame-retardant fabrics that haven't been tested to TB 117-2013 in the actual final product configuration is a common mistake. TB 117 requires testing of the complete finished furniture — fabric, padding, and backing combined — not just the upholstery fabric in isolation.
CARB Phase 2 is more stringent than the federal TSCA Title VI standard. If you're selling nationally — especially to major retailers — CARB Phase 2 is what's expected. TSCA Title VI alone won't cut it. Source materials certified to CARB Phase 2 from the start to ensure you're covered across all platforms.
Yes. TB 117-2013 now applies nationwide because Amazon, Walmart, Costco, and other major retailers enforce it for all upholstered furniture, regardless of where it's sold. It's become the de facto national standard. If you're selling through national retail platforms, TB 117-2013 compliance isn't optional — even for products that never touch California.
Supplier CARB certificates are useful and show solid due diligence, but retailers increasingly want independent verification. Costco conducts its own testing on received products. Supplier documentation is part of the picture, but having independent CARB Phase 2 testing of your finished furniture provides much stronger proof of compliance. If the budget is a constraint, at a minimum, test one representative unit from each supplier batch.
ASTM E1333-16 is the test method — a 24-hour chamber test that measures formaldehyde emissions. CARB Phase 2 is the regulation that sets the emission limits against which test results are measured: 0.09 ppm for plywood, 0.13 ppm for particleboard. When you request CARB Phase 2 certification from a supplier, you should also request the underlying ASTM E1333-16 test results to verify the numbers.
Not necessarily. If all sections use identical fabrics, padding, and backing, one TB 117-2013 test can cover the entire modular set. But if different sections have different fabrics or padding configurations, each unique configuration needs its own test. Check with your testing lab to confirm whether batch testing is acceptable for your specific product.
Costco will delist your product immediately and request that the inventory be returned or destroyed. You're looking at real financial losses and potentially a suspension from selling to Costco until you can demonstrate remediation. That's exactly why independent CARB testing before you ship to retailers matters so much. Don't rely on supplier claims alone — verify compliance through lab testing first.
We coordinate TB 117-2013 testing, CARB Phase 2 verification, tip-over safety certification, lead paint testing, and supplier compliance documentation for furniture products.