HML-04 — Industry overview

Home & Living Compliance Operations

For furniture, textiles, and decor brands — where flammability, formaldehyde, and origin labelling rule shipment readiness.

Regulatory landscape

Home and living products face a multi-layered compliance environment driven by material safety, environmental standards, and timber legality requirements. The regulatory picture is different for the US market versus the EU, and different again for the UK post-Brexit.

Formaldehyde emissions (CARB Phase 2 and TSCA Title VI): Wood composite products — particleboard, MDF, hardwood plywood — must comply with CARB Phase 2 emissions limits in California and TSCA Title VI under US federal law. TSCA Title VI became federal law in 2019 and requires third-party certification of composite wood products from TSCA Title VI TPC (Third Party Certifiers). Furniture containing these materials must carry compliant products or be accompanied by documentation certifying the composite components meet the standard. This is a source of significant customs scrutiny for furniture imports into the US.

Flammability (BS 5852, UK furniture regs): Upholstered furniture sold in the UK must comply with the Furniture and Furnishings (Fire Safety) Regulations 1988, which require materials to pass specified flammability tests. These regulations are UK-specific and do not apply in the same form in the EU, creating a documentation split for brands selling into both markets.

Timber legality (Lacey Act, EUTR/EUDR): The US Lacey Act prohibits trade in timber or wood products that have been illegally harvested in the country of origin. Importers are required to declare species, country of harvest, quantity, and value. The EU Timber Regulation (EUTR) imposed equivalent due diligence requirements, and the incoming EUDR extends this further with deforestation-free requirements and geolocation data. See our EUDR guide →

EN 71-3 (toy safety, applied to children's furniture): Furniture marketed for children's use may need to meet EN 71-3 limits on heavy metals migrating from surface coatings and materials, particularly for painted items and items with fabric that a child might put in their mouth.

CARB Phase 2 TSCA Title VI EN 71-3 BS 5852 (UK Flammability) FSC Chain-of-Custody Lacey Act

EUDR applies to wood and timber products in this category

Wooden furniture components entering the EU are subject to EUDR deforestation-free requirements. This requires geolocation data from the forest of origin and a due diligence statement. See our EUDR guide for current timeline information →

Common compliance pitfalls

Document flow we handle

TSCA Title VI TPC certificates CARB Phase 2 test reports Flammability test certificates (BS 5852) Timber species declarations (Lacey Act) FSC chain-of-custody documentation EUDR due diligence statements EN 71-3 test reports (children's furniture) Hazardous substance declarations Assembly instructions review Care labelling specifications HTS classification decisions

How we'd run an engagement

Home and living compliance engagements typically combine customs documentation with product-level testing coordination. The starting point is a SKU-level audit: for each product, what's the material composition, what's the destination market, and what does the current documentation look like against what's required?

For a furniture brand importing upholstered pieces from Southeast Asia into the US and EU, the engagement covers TSCA certification verification (ensuring the composite wood components carry valid TPC certification, not just a factory COC), CARB emissions test reports for the specific board types used, Lacey Act species declarations at the importer-of-record level, FSC chain-of-custody verification for any FSC-marketed products, and HTS classification validation for each construction type.

For UK-specific compliance, we coordinate flammability test documentation and ensure it's maintained in retrievable format by product batch.

For soft furnishing categories, we handle textile labelling requirements alongside the standard furniture documentation — ensuring that fiber composition and care instruction labels meet both EU Textile Regulation and US Textile Fiber Products Identification Act requirements.

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Example engagement

A furniture brand importing upholstered pieces from Vietnam and Indonesia into the US and EU. We coordinate CARB Phase 2 TSCA Title VI certification verification for the composite wood components, FSC chain-of-custody documentation for FSC-labelled items, Lacey Act timber species declarations at the importer level, flammability test certification for the UK market, and HTS classification for each construction and upholstery type. We also prepare care labelling specifications for the textile components in both EU and US formats.

Frequently asked questions

My factory says their products are CARB compliant. What documentation do I actually need?

For TSCA Title VI compliance (which covers the same substance as CARB Phase 2 at the federal level), you need a certificate from a TSCA-recognized Third Party Certifier (TPC), not just a factory-issued conformance certificate. The TSCA TPC list is maintained by the EPA. If your factory is working with a recognized TPC, they should be able to provide a certificate with the TPC's name and accreditation. If they're issuing their own COC without a TPC, that's not compliant.

We import wooden furniture. Do we need to worry about EUDR?

Yes, if wood is a significant component of what you're importing and it enters the EU market. EUDR requires due diligence statements and geolocation data for wood-based products. The geolocation requirement goes down to the plot of land where the timber was harvested — not just country of origin. This is a significant uplift in documentation requirements for most furniture supply chains. See our EUDR guide for the current implementation timeline.

What does FSC certification actually require from an importer?

Importers who make FSC claims on their products need to hold FSC Chain of Custody (CoC) certification, issued by an FSC-accredited certification body. This is a formal certification process with annual audits. Without it, you cannot label products as FSC-certified even if your supplier has FSC certification. We can help you understand the scope of what's needed, but the certification itself requires engagement with an accredited certifier.

We sell into the UK and the EU. Do we need separate documentation for UK flammability?

Yes. UK flammability regulations for upholstered furniture are specific UK rules that do not have a direct EU equivalent. You need flammability test reports demonstrating compliance with UK regulations for UK-destined products, maintained by batch. EU products are subject to different general product safety requirements under the EU General Product Safety Regulation (GPSR). Maintaining these as separate documentation tracks is the standard approach.

How complex is the Lacey Act declaration?

For furniture with multiple wood components from multiple origins, Lacey Act declarations can be complex. The declaration must cover the scientific name of the species, the country of harvest, quantity, and value. For manufacturers who mix timber species or source from multiple forests, getting accurate species-level information requires working back through the supply chain. We coordinate this documentation collection as part of the engagement.

See how we'd run this for your furniture or home goods operation.

Tell us what you import, where from, and your target markets.

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