NFPA 260 and California Technical Bulletin 117-2013 both measure how well upholstered furniture components resist a smoldering cigarette, but they aren’t interchangeable in the regulatory sense. Since June 25, 2021, TB 117-2013 has been the mandatory federal flammability standard for residential upholstered furniture sold in the United States, codified at 16 CFR Part 1640. NFPA 260 is a voluntary standard, but it’s the one commercial and institutional buyers routinely require in their specifications.
Which Standard Applies to You
Start with the market. If you make, import, or reupholster indoor residential seating for sale in the U.S., TB 117-2013 is not optional. The federal rule at 16 CFR 1640 adopts its test procedures directly and applies to any article of indoor seating furniture with an upholstered seat, back, or arm that contains cushioning or filling material, including children’s furniture.1eCFR. 16 CFR 1640.3 – Definitions Mattresses, foundations, bedding, and fitness equipment are excluded.
If you’re selling into hospitality, healthcare, government buildings, or student housing, the specification sheet will usually call for NFPA 260 Class I. That requirement comes through NFPA 101, the Life Safety Code, which governs fire safety in occupied buildings and requires newly introduced upholstered furniture to resist cigarette ignition. Meeting NFPA 260 Class I is one accepted way to demonstrate compliance.2National Fire Protection Association. NFPA 101 Public Input Report
Manufacturers selling into both markets commonly test to both standards. In most cases the same materials will pass both, but the tests are not identical and a material that barely clears one can fail the other.
How NFPA 260 Tests a Component
NFPA 260 classifies individual upholstered furniture components against a cigarette ignition source. Each component — cover fabric, barrier material, or filling — is tested separately on a standardized foam substrate in a mock-up that forms a crevice between a vertical and a horizontal surface, mimicking where a seat cushion meets a back. A standardized lit cigarette is placed in the crevice and allowed to burn its full length.3National Fire Protection Association. NFPA 260 – Standard Methods of Tests and Classification System for Cigarette Ignition Resistance of Components of Upholstered Furniture
After the cigarette burns out, the tester measures char length. A component with a char length of 1.75 inches or less earns Class I, the highest rating. Anything over that is Class II and generally needs a barrier material behind it to be used safely.
The strength of NFPA 260 is that it isolates each component. Because a Class I fabric is tested against a standard foam rather than against the specific filling a manufacturer plans to use, the result travels with the fabric. A specifier can require “Class I” and know what they’re getting, regardless of the finished furniture’s construction.
How TB 117-2013 Tests a Component
TB 117-2013 tests components within a composite assembly that resembles how the materials will actually sit together. The mock-up is a small plywood structure built to represent a chair seat and back, assembled with a specified standard foam and the component being evaluated.4State of California Department of Consumer Affairs. Technical Bulletin 117-2013
Testing follows a sequence. The cover fabric goes first, with a lit cigarette placed in the crevice on top of the fabric and standard foam. If the fabric passes, the filling materials underneath must be tested separately. If it fails, the manufacturer can still use it by adding a barrier that passes its own test. When barriers and fillings are tested, cotton or cotton-blend sheeting covers the cigarette instead of the actual cover fabric, standardizing that variable.4State of California Department of Consumer Affairs. Technical Bulletin 117-2013
A cover fabric specimen fails if the vertical char length exceeds 1.8 inches, if smoldering continues past 45 minutes, or if the mock-up transitions to open flaming. Three specimens must pass for the fabric to qualify.4State of California Department of Consumer Affairs. Technical Bulletin 117-2013
The Technical Differences That Matter
The two standards address the same hazard with the same ignition source, and the CPSC has described them as “technically equivalent” with “minor variations” that “do not result in different furniture construction, if firms design to pass any or all of the tests.”5U.S. Consumer Product Safety Commission. Upholstered Furniture Update 2019 The variations still matter when a material is near the threshold.
- What gets tested. NFPA 260 rates each component on its own against a standardized companion material. TB 117-2013 tests components inside a composite mock-up and uses the cover fabric result to decide whether barrier testing is needed.
- Char length threshold. NFPA 260 draws its Class I line at 1.75 inches. TB 117-2013 allows up to 1.8 inches of vertical char for cover fabrics, with different thresholds for other component tests within the standard.
- Failure criteria. NFPA 260 relies solely on char length. TB 117-2013 adds two more failure triggers: continued smoldering beyond 45 minutes, and any transition to open flaming.
- Companion material. NFPA 260 uses a standardized foam substrate. TB 117-2013 specifies its own standard non-flame-retardant foam, selected to minimize variation between laboratories.6Bureau of Household Goods and Services. Technical Bulletin 117-2013 FAQ
Neither standard requires materials to resist open-flame ignition. That’s a meaningful change from the original 1975 TB 117, and it’s the reason manufacturers can now meet the current standards using untreated foam.
Labeling the Finished Product
Furniture covered by 16 CFR 1640 must carry a permanent label stating: “Complies with U.S. CPSC requirements for upholstered furniture flammability.” That labeling requirement has applied to all covered furniture manufactured, imported, or reupholstered since June 25, 2022.7eCFR. 16 CFR 1640.4 The label itself is the manufacturer’s certification of compliance; no separate General Certificate of Conformity is required.8U.S. Consumer Product Safety Commission. Upholstered Furniture – Business Guidance FAQ
California layers on an additional requirement. State law requires the label to disclose, in a checkbox format, whether the product contains added flame retardant chemicals. Manufacturers must keep documentation supporting the disclosure, and the state can order testing at the manufacturer’s expense if a product labeled chemical-free tests positive for flame retardants.
Reupholstery: When the Rule Applies
The federal standard reaches reupholstered furniture, but only when the work is done for sale. Having your own couch reupholstered for continued personal use falls outside the rule. A shop that reupholsters furniture to resell, or a person who reupholsters a piece intending to sell it, must use materials that meet TB 117-2013 and apply the compliance label to the finished product.8U.S. Consumer Product Safety Commission. Upholstered Furniture – Business Guidance FAQ
The reupholsterer is only responsible for the materials they add. Original components that stay in the piece don’t need to be retroactively tested or replaced, which matters for antique and restoration work where preserving original materials is the point.