All for Knot — Utah Abandons Digital Law Label Requirements for Bedding, Upholstered Furniture, and Quilted Clothing Retailers

Utah will no longer require online retailers to provide digital law labels or digital textile labels on bedding, upholstered furniture, and quilted clothing product webpages. The digital law label requirements were to go into effect on May 15, 2025. However, the March 1, 2025 issue of the Utah State Bulletin included a notice of substantive change, which proposed the removal of all references to digital law and textile label requirements from Utah’s Bedding, Upholstered Furniture, and Quilted Clothing Rule (R70-101) (the Rule). The revised rule went into effect on April 9, 2024, marking a reversal in the Utah Department of Agriculture and Food’s (UDAF) rulemaking position dating back two years. According to UDAF, the changes to the Rule “reflect the legislative intent to exclude online sales from regulation under [Utah’s Bedding, Upholstered Furniture, and Quilted Clothing] Act.”

Rulemaking History

In April 2023, the UDAF announced that it had revised the Rule to require online retailers of bedding, upholstered furniture, or quilted clothing articles that sell their products to Utah consumers to post digital law labels so that consumers could examine the required information before purchase. On October 3, 2023, UDAF announced that while inspections of online retailers would begin on January 1, 2024, UDAF would not issue penalties for noncompliance, and instead would send notices of violation to the retailers/manufacturers as an educational tool until June 1, 2024.

Before enforcement could begin, on February 15, 2024, UDAF announced that it had temporarily repealed the Rule so that it could conduct a thorough assessment and make necessary adjustments. In June 2024, UDAF filed a notice of substantive change, indicating that the revisions were intended to protect businesses from unfair practices and bolster consumer protection through the online sales requirements listed in the Rule by informing consumers about their online purchases and decreasing the number of items that needed to be returned because they did not meet the consumer’s expectations. In August 2024, UDAF filed another notice of substantive change, indicating that the revisions clarified the definitions for “law label” and “textile label as well as the violation provisions;” outlined the digital labeling requirements for online sales of quilted clothing, bedding, and upholstered furniture; and streamlined the language related to secondhand or used articles. The August 2024 revisions also extended the effective date that online retailers would have to comply with the digital law label and digital textile label requirements until May 15, 2025. Finally, in February 2025, UDAF filed an additional notice of substantive change, proposing the removal of all references to digital law and textile label requirements from the Rule. This notice was published in the March 1, 2025 issue of the Utah State Bulletin. The notice stated that the UDAF would accept comments to the rule change until March 31, 2025 and that the UDAF anticipated making the rule change effective on April 7, 2025. According to the Utah Office of Administrative Rules’ website, the revised rule went into effect on April 9, 2025. 

Current Requirements

Utah’s requirements for permitting, registration, and on-product law labels under the Rule remain unchanged. As it relates to retailers of bedding, upholstered furniture, and quilted clothing in Utah, the rule still requires retailers to ensure: (a) any article of bedding, upholstered furniture, quilted clothing, or filling material sold by the retailer is labeled and tagged correctly; (b) the label complies with state law and the department’s rules governing false and misleading advertisements; (c) the manufacturer from whom a retailer purchases a product has a valid permit with the department; (d) the importer from whom a retailer purchases a product has a valid permit with the department; and (e) the law label or textile label is easily accessible to the consumer for examination.

For questions about Utah’s Bedding, Upholstered Furniture, and Quilted Clothing Rule compliance or other product compliance and safety matters, please reach out to the authors of this Blog post or any of their colleagues on Arnold & Porter’s Consumer Product Safety team.

© Arnold & Porter Kaye Scholer LLP 2025 All Rights Reserved. This Blog post is intended to be a general summary of the law and does not constitute legal advice. You should consult with counsel to determine applicable legal requirements in a specific fact situation.