We would like to request that the State of Virginia rescind the sections in the Bedding regulations that require 1/8” type in the certification clause. We would also like to request that the “Date of Delivery” section of the law tag no longer be required by the State of Virginia.  The regulations concerning these sections have not been enforced in the past.  Maintaining these regulations now will result in a number of economic hardships for the bedding manufacturers and associated suppliers nationwide. 

The second issue is the “Date of Delivery” being required on the label.  In the 2015 ISPA Manual, and IABFLO label example contained in the manual, it is mentioned that a few states require “Date of Delivery” on the label, but they don’t enforce it. The reason being if the “Date of Delivery” does not have to be printed on that line, it is not even necessary to have it at all. This section dates back to when the clerk at the retail store would fill in the date the consumer receives the goods.  Therefore, after the 2015 manual was issued, we had several customers remove “Date of Delivery” from the label.  Now the new 2017 ISPA manual, the IABLFLO label contained in the manual indicates “Date of Delivery” is required to be listed on the label again.  In addition the “Date of Delivery” line is required to be in bold face type and caps and 1/8” font size.  

Since it is required that the certification clause be 1/8” type, and “Date of Delivery” be 1/8” type and bold face, maintenance of these requirements by the State of VA will result in all United States law tags changing.  These changes if maintained would impact hundreds of thousands of labels nationwide.  In most cases, it will cost $25.00 or more to change and re-plate each label.  These changes will involve thousands of man hours of work, which will require type-setting, proofing internally, proofing by the customer, and then replacement of existing plates.  It should also be noted that millions and millions of labels currently in the inventory of manufacturers are now obsolete.  By maintaining these requirements, we will have to increase the size of the labels, which will increase the cost of the labels.  This in turn will result in hundreds of thousands of dollars of additional costs for manufacturers.

Currently manufactures struggle constantly with very narrow profit margins and they are not in a position to pass along increased cost to the retailers, many of whom now are struggling themselves. Finally these regulations will not provide important information to the consumer, and they will not contribute to the consumer’s health and safety. It is for this reason and the reasons stated above, that we respectfully ask that these two sections of the bedding regulations be rescinded.