美国法律标签注册，犹他州线上销售和线下实体销售的新要求

时间：2023-10-07点击次数：615

INTRODUCTION
In April 2023, Utah announced a change to its policy of regulating and inspecting online retailers. The change essentially means that online sales of bedding and furniture products (not toys) will be required to display a law label on each product page like is done for products sold in retail stores.

The implementation date is January 1, 2024.

However, the UT office announced on October 3, 2023, that they will begin the inspections on January 1, 2024, but with no actual penalty. They are calling it a “soft enforcement” for the first 6 months. Violation notices will be sent to the retailers/manufacturers as an educational tool until June 1, 2024.

IMPLEMENTATION TIMELINE
>> Present day through December 31, 2023: No requirement for online retailers/resellers
>> January 1, 2024 through June 1, 2024: Violations will be issued, but no penalties
>> June 1, 2024: Violations will be issued with standard penalties


PENALTIES FOR VIOLATIONS
According to the UT office: “Violations of the Utah Agricultural Code are punishable either as a Class B misdemeanor, by citation of up to $500.00, or civilly by fines of up to $5,000.00 per occurrence.”

We have never had a customer receive a penalty like these above.

Almost all violations can be resolved with a letter to the UT office, a renewal of an overdue registration or a change to the label design, depending on what the violation is for.

The UT office wants to work with the company to be compliant with their laws. They do not wish to enforce harsh penalties unless it is absolutely necessary. It would take a lot of failure by the company to receive a harsh penalty.


WHO IS AFFECTED
All companies who have a website or use a 3rd party website like Amazon, Wayfair and others, to sell or resell their bedding and furniture products. This applies to retailers and “direct-to-customer” foreign manufacturers/resellers.

Essentially, any bedding or furniture product that is required to have a law label on it, is now required to have a copy of the law label on the website product page.

SOLUTION
The UT law does not say exactly how the law label is to be displayed, only that it must be displayed to the consumer, so there is some room for creativity as to where the law label will be put on the product page.

We are recommending a simple solution of adding a picture of the law label to the product pictures on the product page of the affected website. The law label can also be put in the Instructions/Warnings/Manuals/Etc. section of the product page as a .pdf or .jpg file.

All companies, including retailers and “direct-to-customer” foreign manufacturers/resellers, who have a website or use a 3rd party website like Amazon, Wayfair and others, will need to update the product page with an image or file of a law label.

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