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Imported furniture and due diligence
All upholstered domestic furniture sold in the UK must meet the Furniture and Furnishings (Fire) (Safety) Regulations 1988 (as amended in 1989, 1993 and 2010).
Retailers who sell imported upholstery should ask their suppliers for documentation that proves that the furniture they intend to display and sell is compliant with these regulations. When a retailer imports furniture it becomes the ‘first supplier’ within the meaning of the regulations and it is the retailer’s responsibility to ensure the furniture complies. Compliance should never be assumed. Evidence in the form of test reports or certificates for each batch of products should be obtained.
The UK Furniture and Furnishings (Fire) (Safety) Regulations 1988 (as amended) are generally regarded as the most severe in the world. Indeed, in many countries there are no flammability requirements of any sort in place. Consequently foreign producers may not be fully familiar with UK furniture safety specifications. In fact, these UK regulations demand foam formulations that are, in many instances, not used or even produced in some countries.
|Table 1: The tests relevant for domestic upholstered chairs and sofas
|Description of furniture component and type of test required
|Schedules as specified in the Furniture and Furnishings (Fire) (Safety) Regulations 1988 (as amended)
|Urethane foam in block or moulded form
|Schedule 1 Part I
|Non-foam filling (for instance, loose fibre)
|Schedule 2 Part I
|Covers – match test
Covers and fillings together forming a composite – cigarette test
|Schedule 5 Part I
Schedule 4 Part I
|Cover material of special construction - 75 per cent cotton, viscose, modal, flax, silk, or wool (individually or in combination): cigarette test
|Schedule 4 Part I
|Non-visible covers including platform cloth and dust cover material
|Schedule 5 Part III and Schedule 4 Part II
|The above table lists the main tests required under the UK regulations. Other tests may be needed to demonstrate compliance depending upon materials used in the furniture. The schedules specify various, dated, British Standard test methods, which should be referred to for further information.
Test reports offered by the supplier should contain the relevant test data. Only results from the tests specified in the schedules to the regulations, which are based on past issues of BS 5852, are of any value.
SATRA recommends that retailers ask to see test reports that are produced by an independent laboratory, ideally with accreditation to ISO/IEC 17025:2017 – 'General requirements for the competence of testing and calibration laboratories' (for example, by the United Kingdom Accreditation Service – UKAS) for the relevant tests.
For due diligence purposes, retailers should carry out spot checks on materials to verify the compliance of imported items. Most importantly, assurances should be provided that the materials tested are representative of those used in the furniture. If the materials are found to be different, the reports are worthless. If there is any doubt, the retailer should request additional tests. We also advise that any dates on the test report are checked thoroughly. There are no rules, but reports older than six months will not inspire confidence.
Retailers are also advised to check for test results that relate to precise batches of materials and subsequent batches or single items of furniture that are shipped to the UK. If the furniture is made outside the UK, the manufacturer is not legally responsible for compliance. However, if it has a UK-based agent or office, the enforcement authorities may expect the UK-based operation or branch to be responsible for demonstrating compliance. In all cases, retailers have a responsibility to offer only compliant furniture to their customers. Retailers who import upholstered furniture should ensure that the specifications of products do not vary after testing has been completed. If they do, further testing is required.
Trade furniture buyers should insist on being supplied with test reports and data for all parts of the furniture, for example covers, dust covers, platform cloths, interliners where appropriate, and every foam and non-foam filling. See figure 1 for an explanation as to what parts of a sofa need to be tested to comply with the regulations, and table 1 for a list of relevant tests.
To summarise, test reports will help the retailer demonstrate that its products are truly compliant. Secondly, they provide a basis for a defence of due diligence should a trading standards officer procure an item, test it and find it does not comply. Repeat testing of materials will reinforce the retailer’s argument that it has done all it can to ensure that only compliant furniture was displayed or supplied.
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