EUROFINS MTS TEST PROTOCOL

SUMMARY OF TEST RESULTS FOR

SP - 951 - Costco
Flame Retardant Restrictions Supplemental Protocol
Client Code: Technician: Report Number:
Start Date: Finish Date: Result Reviewed by:

TEST CODE TESTED PROPERTY REQUIREMENT RESULTS COMMENTS

Pass Fail
Scope: This protocol is applicable to Flame Retardant Restrictions for US, Canada, UK, France, Spain, Iceland,
Sweden and Korea.

Instruction for Testing:

1. If the tested product is within the scope of CSS (Costco Smart Screening) testing, CSS should be conducted.
2. For product outside the scope of CSS, conduct testing via LC-MS or GC-MS (or a combination of both
techniques).
3. If the product/component is certified by OEKO-TEX / Bluesign / Cradle to Cradle (Silver certification level and
higher) and EPA Safer Choice, it can be exempted from Flame Retardant Chemicals Test.

ANALYTICAL
US
HI, MD, OR / * Flame retardant in all All products shall not contain more than
Solvent products 1000 ppm of (deca–BDE)
Extraction. Decabromodiphenyl ether, (octa–BDE)
Octabromodiphenyl ether or (penta–BDE)
Analyzed by
Pentabromodiphenyl ether
GC/MS
MD: (deca–BDE) Decabromodiphenyl ether
is prohibited

Note:
​- Actual testing shall be conducted on
accessible and inaccessible polyurethane
and polystyrene foam materials and all
upholstery, excluding leather, covering
polyurethane and polystyrene foam
materials.
- Vendors shall provide a letter of
guarantee that flame​ ​retardants have not
been added. If vendor cannot provide this,
then all foams, textiles and plastics shall be
tested.
- Vendors shall provide documentation or a
bill of materials for material identification of
polyurethane and polystyrene foams. If they
cannot provide this information, all foam
materials and all upholstery, excluding
leather, covering foam materials will be
tested.
- Composite up to 3 like materials (except
metals).
- Individual materials will be analyzed if the
composite result exceeds the adjusted limit
(regulatory limit divided by the number of
components).
- Vendor shall be responsible for the

Latest revision: 7 Sep 2023 Page 1 of 29

 EUROFINS MTS TEST PROTOCOL

SUMMARY OF TEST RESULTS FOR

SP - 951 - Costco
Flame Retardant Restrictions Supplemental Protocol
Client Code: Technician: Report Number:
Start Date: Finish Date: Result Reviewed by:

TEST CODE TESTED PROPERTY REQUIREMENT RESULTS COMMENTS

Pass Fail
ME, VT / * Flame retardant in all Products shall meet the following
Solvent products requirements:
Extraction. 1. All products shall not contain more than
1000 ppm of (octa–BDE)
Analyzed by
Octabromodiphenyl ether or (penta–BDE)
GC/MS
Pentabromodiphenyl ether
2. Mattress, mattress pads, upholstered
furniture, computers, televisions and
shipping pallets shall not contain more than
1000 ppm of (deca–BDE)
Decabromodiphenyl ether

Note:
​- Actual testing shall be conducted on
accessible and inaccessible polyurethane
and polystyrene foam materials and all
upholstery, excluding leather, covering
polyurethane and polystyrene foam
materials.
- Vendors shall provide a letter of
guarantee that flame​ ​retardants have not
been added. If vendor cannot provide this,
then all foams, textiles and plastics shall be
tested.
- Vendors shall provide documentation or a
bill of materials for material identification of
polyurethane and polystyrene foams. If they
cannot provide this information, all foam
materials and all upholstery, excluding
leather, covering foam materials will be
* Flame retardant in all - Composite up to 3 like materials (except
products metals).
- Individual materials will be analyzed if the
(Continued) composite result exceeds the adjusted limit
(regulatory limit divided by the number of
components).
- Vendor shall be responsible for the
compliance of all other materials and all
other children's products.

Latest revision: 7 Sep 2023 Page 2 of 29

 EUROFINS MTS TEST PROTOCOL

SUMMARY OF TEST RESULTS FOR

SP - 951 - Costco
Flame Retardant Restrictions Supplemental Protocol
Client Code: Technician: Report Number:
Start Date: Finish Date: Result Reviewed by:

TEST CODE TESTED PROPERTY REQUIREMENT RESULTS COMMENTS

Pass Fail
WA / * Flame retardant in all Products shall meet the following
Washington products requirements:
State 1. All products shall not contain
Polybrominated diphenyl ethers
Polybrominat
2. Mattress, mattress pads, upholstered
ed Diphenyl
furniture, computers, televisions and
Ether shipping pallets shall not contain
(PBDE) (deca–BDE) Decabromodiphenyl ether
Chemical
Action Plan: Note:
Final Plan / ​-Actual testing shall be conducted on
Solvent accessible and inaccessible polyurethane
Extraction. and polystyrene foam materials and all
Analyzed by upholstery, excluding leather, covering
polyurethane and polystyrene foam
GC/MS
materials.
- Vendors shall provide a letter of
guarantee that flame​ ​retardants have not
been added. If vendor cannot provide this,
then all foams, textiles and plastics shall be
tested.
- Vendors shall provide documentation or a
bill of materials for material identification of
polyurethane and polystyrene foams. If they
cannot provide this information, all foam
materials and all upholstery, excluding
leather, covering foam materials will be
tested.

Reference:
https://app.leg.wa.gov/rcw/default.aspx?cite
* Flame retardant in all - Composite up to 3 like materials (except
products metals).
- Individual materials will be analyzed if the
(Continued) composite result exceeds the adjusted limit
(regulatory limit divided by the number of
components).
- Vendor shall be responsible for the
compliance of all other materials and all
other children's products.

Latest revision: 7 Sep 2023 Page 3 of 29

 EUROFINS MTS TEST PROTOCOL

SUMMARY OF TEST RESULTS FOR

SP - 951 - Costco
Flame Retardant Restrictions Supplemental Protocol
Client Code: Technician: Report Number:
Start Date: Finish Date: Result Reviewed by:

TEST CODE TESTED PROPERTY REQUIREMENT RESULTS COMMENTS

Pass Fail
Washington * Flame retardants - Electric Restriction: Shall not contain intentionally
Safer and electronic products with added organohalogen flame retardants.
Products plastic external enclosures,
intended for indoor use. Note: Ecology presumes the detection of:
Restrictions
(A) Total bromine concentrations above
and
Apply to electric and 1,000 ppm indicate inten-tionally added
Reporting electronic products with organohalogen flame retardants.
WAC 173- plastic external enclosures, (B) Total chlorine concentrations above
337-112 (1) intended for indoor use that 1,000 ppm indicate inten-tionally added
are powered by either of the organohalogen flame retardants.
following: (C) Total fluorine concentrations above
(A) Standard 120 volt outlets 1,000 ppm with less than 5,000 ppm total
and designed for up to 20 phosphorus indicate intentionally added
amp circuit; organohalogen flame retardants.
(B) Battery.
Effective Date:
Electronic display and Televisions: January
1, 2025
Group 1: January 1, 2027
Group 2: January 1, 2028
Washington * Flame retardants - Electric Reporting:
Safer and electronic products with The manufacturer must provide notice that
Products plastic external enclosures, the priority consumer product " Electric and
intended for outdoor use. electronic products with plastic external
Restrictions
enclosures, intended for outdoor use."
and
Applies to electric and contains intentionally added organohalogen
Reporting electronic products with flame retardant. The manufacturer must
WAC 173- plastic external enclosures, provide notice to ecology in accordance
337-112 (2) intended for outdoor use that with WAC 173-337-060.
are powered by either of the
following: Note: Ecology presumes the detection of:
(A) Standard 120 volt outlets (A) Total bromine concentrations above
and designed for up to 20 1,000 ppm indicate inten-tionally added
amp circuit; organohalogen flame retardants.
(B) Battery. (B) Total chlorine concentrations above
1,000 ppm indicate inten-tionally added
organohalogen flame retardants.
(C) Total fluorine concentrations above
1,000 ppm with less than 5,000 ppm total
phosphorus indicate intentionally added
organohalogen flame retardants.

Effective Date:
January 1, 2024

Latest revision: 7 Sep 2023 Page 4 of 29

 EUROFINS MTS TEST PROTOCOL

SUMMARY OF TEST RESULTS FOR

SP - 951 - Costco
Flame Retardant Restrictions Supplemental Protocol
Client Code: Technician: Report Number:
Start Date: Finish Date: Result Reviewed by:

TEST CODE TESTED PROPERTY REQUIREMENT RESULTS COMMENTS

Pass Fail
Washington * Flame retardants - Reporting:
Safer Recreational covered wall The manufacturer must provide notice that
Products padding made from the priority consumer product "
polyurethane foam Recreational covered wall padding made
Restrictions
from polyurethane foam" contains
and
Organohalogen flame intentionally added organohalogen flame
Reporting retardant retardant. The manufacturer must provide
WAC 173- .• Ethylhexyl diphenyl notice to ecology in accordance with WAC
337-112 (3) phosphate (EHDPP, CAS 173-337-060.
RN: 1241-94-7);
• Isopropylated triphenyl Note: Ecology presumes the detection of:
phosphate (IPTPP, CAS RN: (ii) Ecology presumes the detection of:
68937-41-7); (A) Total bromine concentrations above
[ 14 ] OTS-4159.1 1,000 ppm indicate intentionally added
• Tributyl phosphate (TNBP, organohalogen flame retardants.
CAS RN: 126-73-8); (B) Total chlorine concentrations above
• Triorthocresyl phosphate 1,000 ppm indicate intentionally added
(TCP, CAS RN: 1330-78-5); organohalogen flame retardants.
• Triphenyl phosphate (TPP, (C) Total fluorine concentrations above
CAS RN: 115-86-6). 1,000 ppm indicate inten-tionally added
organohalogen flame retardants.
(D) Organophosphate flame retardants
listed in this subsection (individual or
combined) at concentrations above 1,000
ppm indicate intentionally added
organophosphate flame retardants.

Effective Date:

Latest revision: 7 Sep 2023 Page 5 of 29

 EUROFINS MTS TEST PROTOCOL

SUMMARY OF TEST RESULTS FOR

SP - 951 - Costco
Flame Retardant Restrictions Supplemental Protocol
Client Code: Technician: Report Number:
Start Date: Finish Date: Result Reviewed by:

TEST CODE TESTED PROPERTY REQUIREMENT RESULTS COMMENTS

Pass Fail
Washington * Flame retardants - Other Restriction: Shall not contain intentionally
Safer recreational products made added organohalogen flame retardants.
Products from polyurethane foam
Note: Ecology presumes the detection of:
Restrictions
This subsection applies to: (ii) Ecology presumes the detection of:
and
(A) Recreational covered (A) Total bromine concentrations above
Reporting flooring made from 1,000 ppm indicate inten-tionally added
WAC 173- polyurethane foam; organohalogen flame retardants.
337-112 (4) (B) Recreational covered (B) Total chlorine concentrations above
mats made from 1,000 ppm indicate inten-tionally added
polyurethane foam; organohalogen flame retardants.
(C) Outdoor recreational (C) Total fluorine concentrations above
products made from 1,000 ppm indicate inten-tionally added
polyurethane foam; organohalogen flame retardants.
(D) Uncovered recreational (D) Organophosphate flame retardants
products made from listed in this subsection (individual or
polyurethane foam. combined) at concentrations above 1,000
(ii) This subsection does not ppm indicate intentionally added
apply to: organophosphate flame retardants.
(A) Recreational covered
wall padding made from Effective Date:
polyurethane foam. January 1, 2025
(B) Outdoor playground
equipment.
Organohalogen flame
retardant
.• Ethylhexyl diphenyl
phosphate (EHDPP, CAS
RN: 1241-94-7);
• Isopropylated triphenyl
phosphate (IPTPP, CAS RN:
68937-41-7);
[ 14 ] OTS-4159.1
• Tributyl phosphate (TNBP,
CAS RN: 126-73-8);
• Triorthocresyl phosphate

Latest revision: 7 Sep 2023 Page 6 of 29

 EUROFINS MTS TEST PROTOCOL

SUMMARY OF TEST RESULTS FOR

SP - 951 - Costco
Flame Retardant Restrictions Supplemental Protocol
Client Code: Technician: Report Number:
Start Date: Finish Date: Result Reviewed by:

TEST CODE TESTED PROPERTY REQUIREMENT RESULTS COMMENTS

Pass Fail
CA, MN, NY, * Flame retardant in all All products shall not contain more than
IL, RI, products 1000 ppm of (octa–BDE)
MI / Octabromodiphenyl ether and (penta–BDE)
Pentabromodiphenyl ether
Solvent
Extraction.
Note:
Analyzed by ​- Actual testing shall be conducted on
GC/MS accessible and inaccessible polyurethane
and polystyrene foam materials and all
upholstery, excluding leather, covering
polyurethane and polystyrene foam
materials.
​- Vendors shall provide a letter of
guarantee that flame​ ​retardants have not
been added. If vendor cannot provide this,
then all foams, textiles and plastics shall be
tested.​ Failure should be issued for not
provided LoG​
- Vendors shall provide documentation or a
bill of materials for material identification of
polyurethane and polystyrene foams. If they
cannot provide this information, all foam
materials and all upholstery, excluding
leather, covering foam materials will be
tested.
- Composite up to 3 like materials (except
metals).
- Individual materials will be analyzed if the
composite result exceeds the adjusted limit
(regulatory limit divided by the number of
components).
- Vendor shall be responsible for the
compliance of all other materials and all
San * Flame retardant in Upholstered furniture, Reupholstered
Francisco upholstered furniture or furniture, Juvenile products for residential
Flame bedding, reupholstered use, Products above with electrical or
furniture, juvenile products electronic components, shall not contain
Retardant
for residential use more than 1000 ppm any flame retardant
Ban
chemicals.
(Ordinance
No. 211-17) / If flame retardants are found during any
Document analytical testing in the Costco Smart
Review Screening or normal analytical testing,
failure(s) should be issued for San
Francisco as applicable (even if an LoG
was previously received).
Report actual results or include data table
within report.

Latest revision: 7 Sep 2023 Page 7 of 29

 EUROFINS MTS TEST PROTOCOL

SUMMARY OF TEST RESULTS FOR

SP - 951 - Costco
Flame Retardant Restrictions Supplemental Protocol
Client Code: Technician: Report Number:
Start Date: Finish Date: Result Reviewed by:

TEST CODE TESTED PROPERTY REQUIREMENT RESULTS COMMENTS

Pass Fail
Definition:
- Children's product means designed for residential use by infants and children under 12 years of age, including but not
limited to a bassinet, booster seat, changing pad, floor play mat, highchair, highchair pad, infant bouncer, infant carrier,
infant seat, infant swing, infant walker, nursing pad, nursing pillow, playpen side pad, playard, portable hook-on chair,
stroller, and children's nap mat. Children's Products do not include:
(a) products that are not primarily intended for use in the home, such as products or components for motor vehicles,
watercraft. aircraft. or other vehicles;
(b) products subject to Title 49, Part 571 of the Code of Federal Regulations regarding parts and products used in
vehicles and aircraft;
(c) products required to meet federal flammability standards in Title 16, Parts 1632 or 1633 of the Code of Federal
Regulations regarding mattress products; and
(d) products required to meet State flammability standards in California Technical 6 Bulletin 13 3, entitled "Flammability
Test Procedure for Seating Furniture for Use in Public Occupancies. "

Note:
- Actual testing shall be conducted on accessible and inaccessible polyurethane and polystyrene foam materials and all
upholstery, excluding leather, covering polyurethane and polystyrene foam materials.
- Vendors shall provide a letter of guarantee that flame retardants have not been added. If vendor cannot provide this,
then all foams, textiles and plastics shall be tested.
- Vendors shall provide documentation or a bill of materials for material identification of polyurethane and polystyrene
foams. If they cannot provide this information, all foam materials and all upholstery, excluding leather, covering foam
materials will be tested.
- Composite up to 3 like materials (except metals).
- Individual materials will be analyzed if the composite result exceeds the adjusted limit (regulatory limit divided by the
number of components).
- Vendor shall be responsible for the compliance of all other materials and all other children's products.

Maine * Flame retardant in Upholstered furniture shall not contain

Flame residential upholstered more than 0.1% of a flame-retardant
Retardant furniture chemical or more than 0.1% of a mixture
that includes flame-retardant chemicals.
Ban (H.P.
138 - L.D.
If flame retardants are found during any
182) / analytical testing in the Costco Smart
Document Screening or normal analytical testing,
Review failure(s) should be issued for Maine as
applicable (even if an LoG was previously
received).
Report actual results or include data table
within report.

Definition:
"Flame-retardant chemical" means a chemical or chemical compound for which a functional use is to resist or inhibit the
spread of fire. "Flame-retardant chemical" includes, but is not limited to, halogenated, phosphorus-based, nitrogen-based
and nanoscale flame retardants and any chemical or chemical compound for which "flame retardant" appears on the
substance safety data sheet required under 29 Code of Federal Regulations, Section 1910.1200(g) (2015).

"Upholstered furniture" means residential furniture intended for indoor use in a home or other dwelling intended for
residential occupancy that consists in whole or in part of resilient cushioning materials enclosed within a covering
consisting of fabric or related materials.

Latest revision: 7 Sep 2023 Page 8 of 29

 EUROFINS MTS TEST PROTOCOL

SUMMARY OF TEST RESULTS FOR

SP - 951 - Costco
Flame Retardant Restrictions Supplemental Protocol
Client Code: Technician: Report Number:
Start Date: Finish Date: Result Reviewed by:

TEST CODE TESTED PROPERTY REQUIREMENT RESULTS COMMENTS

Pass Fail
Note:
- Actual testing shall be conducted on accessible and inaccessible polyurethane and polystyrene foam materials and all
upholstery, excluding leather, covering polyurethane and polystyrene foam materials.
- Vendors shall provide a letter of guarantee that flame retardants have not been added. If vendor cannot provide this,
then all foams, textiles and plastics shall be tested.
- Vendors shall provide documentation or a bill of materials for material identification of polyurethane and polystyrene
foams. If they cannot provide this information, all foam materials and all upholstery, excluding leather, covering foam
materials will be tested.
- Composite up to 3 like materials (except metals).
- Individual materials will be analyzed if the composite result exceeds the adjusted limit (regulatory limit divided by the
number of components).
- Vendor shall be responsible for the compliance of all other materials and all other children's products.

Rhode Island * Flame retardant in Any residential upholstered bedding or

(H 5119) residential upholstered furniture shall not contain more than 1000
bedding or furniture ppm of any non-polymeric organohalogen
flame retardant chemical. This class
includes any chemical containing the
element bromine or chlorine bonded to
carbon that is added to a plastic, foam,
fabric, or textile.

Definition:
"Bedding" or "article of bedding" includes upholstered furniture and filling material or its container (as herein defined) and
any mattress, pillow, cushion, quilt, bedpad, comforter, upholstered spring bed, box spring, davenport or day bed, bed
spring, metal couch, metal folding bed, metal cot, metal cradle, metal bassinet, and any glider, hammock, or other
substantially similar article which is wholly or partly upholstered, when used or intended for use for sleeping or reclining
purposes.
"Upholstered furniture" means any article of household furniture wholly or partly stuffed or filled with soft material, and
which is used or intended for use for sitting, reading, or reclining purposes.
Note:
- Actual testing shall be conducted on accessible and inaccessible polyurethane and polystyrene foam materials and all
upholstery, excluding leather, covering polyurethane and polystyrene foam materials.
- Vendors shall provide a letter of guarantee that flame retardants have not been added. If vendor cannot provide this,
then all foams, textiles and plastics shall be tested.
- Vendors shall provide documentation or a bill of materials for material identification of polyurethane and polystyrene
foams. If they cannot provide this information, all foam materials and all upholstery, excluding leather, covering foam
materials will be tested.
- Composite up to 3 like materials (except metals).
- Individual materials will be analyzed if the composite result exceeds the adjusted limit (regulatory limit divided by the
number of components).
- Vendor shall be responsible for the compliance of all other materials and all other children's products.

Latest revision: 7 Sep 2023 Page 9 of 29

 EUROFINS MTS TEST PROTOCOL

SUMMARY OF TEST RESULTS FOR

SP - 951 - Costco
Flame Retardant Restrictions Supplemental Protocol
Client Code: Technician: Report Number:
Start Date: Finish Date: Result Reviewed by:

TEST CODE TESTED PROPERTY REQUIREMENT RESULTS COMMENTS

Pass Fail
Massachuset * Flame retardant in bedding, Any component part of bedding, carpeting,
ts carpeting, children's product, children's product, residential upholstered
(Bill H.4900) residential upholstered furniture or window treatment shall not
furniture or window treatment contain more than 1000 ppm of following
chemical flame retardants or a chemical
analogue:
1. Tris(1,3-dichloro-2-propyl)phosphate
(TDCPP);
2. Tris(2-chloroethyl)phosphate (TCEP);
3. Antimony trioxide;
4. Hexabromocyclododecane (HBCD);
5. Bis(2-Ethylhexyl)-3,4,5,6-
tetrabromophthalate (TBPH);
6. 2-EthylhexYl-2,3,4,5-tetrabromobenzoate
(TBB);
7. Chlorinated paraffins;
8. Tris (1-chloro-2-propyl) phosphate
(TCPP);
9. PentaBDE;
10. OctaBDE;
11. Tetrabromobisphenol A (TBBPA)

Exemption:
Any covered product manufactured before
December 31, 2021 or any covered product
that contains chemicals prohibited under
this section due to the presence of recycled
materials used during the manufacture of
the product covered
Definition:
"Bedding" means any bedding material including, but not limited to, a mattress, mattress pad, mattress cover, sheeting,
pillow, blanket, comforter, duvet cover, sleeping bag or any other stuffed item intended to be used for reclining or
sleeping.
"Carpeting" means any fabric floor covering, including carpet padding.
"Children's product" means a consumer product intended, made or marketed for use by children 12 years of age or under.
"Residential upholstered furniture" means seating or other upholstered products intended for indoor or outdoor use in or at
a home or other dwelling intended for residential occupancy that consists in whole or in part of resilient cushioning
materials enclosed within a covering consisting of fabric or other textile.
"Window treatment" means curtain materials blinds or shades
Note:
- Actual testing shall be conducted on accessible and inaccessible polyurethane and polystyrene foam materials and all
upholstery, excluding leather, covering polyurethane and polystyrene foam materials.
- Vendors shall provide a letter of guarantee that flame retardants have not been added. If vendor cannot provide this,
then all foams, textiles and plastics shall be tested.
- Vendors shall provide documentation or a bill of materials for material identification of polyurethane and polystyrene
foams. If they cannot provide this information, all foam materials and all upholstery, excluding leather, covering foam
materials will be tested.
- Composite up to 3 like materials (except metals).
- Individual materials will be analyzed if the composite result exceeds the adjusted limit (regulatory limit divided by the
number of components).
- Vendor shall be responsible for the compliance of all other materials and all other children's products.

Latest revision: 7 Sep 2023 Page 10 of 29

 EUROFINS MTS TEST PROTOCOL

SUMMARY OF TEST RESULTS FOR

SP - 951 - Costco
Flame Retardant Restrictions Supplemental Protocol
Client Code: Technician: Report Number:
Start Date: Finish Date: Result Reviewed by:

TEST CODE TESTED PROPERTY REQUIREMENT RESULTS COMMENTS

Pass Fail
NY, MD, * Flame retardant in Residential upholstered furniture and
WA, VT, HI, upholstered furniture and products for children under the age of
ME, NV and children’s products twelve shall not contain more than 1000
ppm of Tris(2-chloroethyl) phosphate
OR State
(TCEP) , hexabromocyclododecane
CSPA /
(HBCDD), tetrabromobisphenol A (TBBPA),
Children’s Tris(1,3-dichloro-2-propyl) phosphate
Safe (TDCPP ) or (Deca–BDE)
Products Act Decabromodiphenyl ether
Law,
Chapter Report actual results or include data table
70.240 RCW within report.
/ Solvent
Extraction. Note :
- Actual testing shall be conducted on
Analyzed by
residential upholstered furniture and the
GC/MS
following products for children: toys,
cosmetics, jewelry, products designed or
intended by the manufacturer to help a
child with sucking or teething, to facilitate
sleep, relaxation, or the feeding of a child,
or to be worn as clothing by children, and
child car seats.
- Refer to CSPA Reporting Rule WAC 173-
334 for the complete children's products
list.
- See RCW Chapter 70.240.010 for
children's products that are exempt.
- Actual testing shall be conducted on
accessible and inaccessible polyurethane
and polystyrene foam materials and all
upholstery, excluding leather, covering
polyurethane and polystyrene foam
* Flame retardant in - Vendors shall provide a letter of
upholstered furniture and guarantee that flame retardants have not
children’s products been added. If vendor cannot provide this,
then all foams, textiles and plastics shall be
(Continued) tested.
- Vendors shall provide documentation or a
bill of materials for material identification of
polyurethane and polystyrene foams. If they
cannot provide this information, all foam
materials and all upholstery, excluding
leather, covering foam materials will be
tested.
- Composite up to 3 like materials (except
metals).
- Individual materials will be analyzed if the
composite result exceeds the adjusted limit
(regulatory limit divided by the number of
components).
- Vendor shall be responsible for the
compliance of all other materials.

Latest revision: 7 Sep 2023 Page 11 of 29

 EUROFINS MTS TEST PROTOCOL

SUMMARY OF TEST RESULTS FOR

SP - 951 - Costco
Flame Retardant Restrictions Supplemental Protocol
Client Code: Technician: Report Number:
Start Date: Finish Date: Result Reviewed by:

TEST CODE TESTED PROPERTY REQUIREMENT RESULTS COMMENTS

Pass Fail
MN / * Flame retardant chemicals Children's product, upholstered residential
Minnesota in children’s product, furniture, residential textile, or mattress
Statutes upholstered residential shall not contain more than 1,000 ppm in
furniture, residential textile, any product component any
2018,
or mattress organohalogenated flame retardant
section
chemical.
325F.071 /
Solvent Report actual results or include data table
Extraction. within report.
Analyzed by
GC/MS Note :
- Children's product means a product
primarily designed or intended by a
manufacturer to be used by or for a child,
including any article used as a component
of such a product, but excluding a food,
beverage, dietary supplement,
pharmaceutical product or biologic,
children's toys, a medical device
- Upholstered residential furniture means
furniture with padding, coverings, and
cushions intended
and sold for use in the home
- Residential textile means a textile
designed for use in the home as a covering
on windows or walls
- Refer Subdivision 2a. in Minnesota
Statutes 2018, section 325F.071, for
* Flame retardant chemicals - Vendors shall provide a letter of
in children’s product, guarantee that flame retardants have not
upholstered residential been added. If vendor cannot provide this,
furniture, residential textile, then all foams, textiles and plastics shall be
or mattress tested.
- Vendors shall provide documentation or a
(Continued) bill of materials for material identification of
polyurethane and polystyrene foams. If they
cannot provide this information, all foam
materials and all upholstery, excluding
leather, covering foam materials will be
tested.
- Composite up to 3 like materials (except
metals).
- Individual materials will be analyzed if the
composite result exceeds the adjusted limit
(regulatory limit divided by the number of
components).
- Vendor shall be responsible for the
compliance of all other materials and all
other children's products.
Vermont / * Flame retardant in Residential upholstered furniture and
Solvent upholstered furniture and products for children under the age of
Extraction. children’s products and twelve shall not contain more than 1000
Analyzed by mattress or mattress pad ppm of Tris(2-chloroethyl) phosphate
(TCEP) or Tris(1,3-dichloro-2-propyl)
GC/MS
phosphate (TDCPP)
(S81)
Report actual results or include data table
within report.

Latest revision: 7 Sep 2023 Page 12 of 29

 EUROFINS MTS TEST PROTOCOL

SUMMARY OF TEST RESULTS FOR

SP - 951 - Costco
Flame Retardant Restrictions Supplemental Protocol
Client Code: Technician: Report Number:
Start Date: Finish Date: Result Reviewed by:

TEST CODE TESTED PROPERTY REQUIREMENT RESULTS COMMENTS

Pass Fail
New York * Flame retardant in child Child care products for children under 3
Environment care products years of age shall not contain any
al detectable level of Tris(2-chloroethyl)
phosphate (TCEP) and Tris(1,3-dichloro-2-
Conservation
propyl) phosphate (TDCPP).
- Title 7 - (37-
0701 - 37- Report actual results or include data table
0709) within report.
Tris-Free
Children and Note:
Babies Act/ - Child care products for children under 3
years of age include but are not limited to
toys, car seats, nursing pillows, crib
mattresses, high chairs and strollers.
- Actual testing shall be conducted on
accessible and inaccessible polyurethane
and polystyrene foam materials and all
upholstery, excluding leather, covering
polyurethane and polystyrene foam
materials.
- Vendors shall provide a letter of
guarantee that flame retardants have not
been added. If vendor cannot provide this,
then all foams, textiles and plastics shall be
tested.
- Vendors shall provide documentation or a
bill of materials for material identification of
polyurethane and polystyrene foams. If they
cannot provide this information, all foam
materials and all upholstery, excluding
leather, covering foam materials will be
tested.
- Vendors shall be responsible for the
compliance of all other materials

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 EUROFINS MTS TEST PROTOCOL

SUMMARY OF TEST RESULTS FOR

SP - 951 - Costco
Flame Retardant Restrictions Supplemental Protocol
Client Code: Technician: Report Number:
Start Date: Finish Date: Result Reviewed by:

TEST CODE TESTED PROPERTY REQUIREMENT RESULTS COMMENTS

Pass Fail
New York * New York State ≤ 100 mg/kg for each of the CoC/ HPC on
Toxic Toxic chemicals in Children the current list
chemicals in Products - Toxic Chemicals
in Children's Products The list of Chemicals of Concern (CoC) /
children's
High Priority Chemicals (HPC) was
products,
referenced from reporting list of Toxic
Title IX,
chemicals in children's products, Title IX,
Article 37, Article 37, New York Environmental
New York Conservation Law
Environment https://nyassembly.gov/leg/?default_fld=&le
al g_video=&bn=A09765&term=2019&Summ
Conservation ary=Y&Actions=Y&Text=Y
Law /
Analysis is Effective January 1st, 2023, a children's
based on product containing any of the following High
Priority Chemicals shall be prohibited from
GC, LC, IC,
distribution or sale:
ICP, with • Tris(1,3-dichloro-2-propyl) phosphate
various (TDCPP)
detection • Benzene
techniques • Asbestos
and UV
Manufacturers must provide Biennial Notice
to the New York Department of
Environmental Conservation of children's
products sold or offered for sale in New
York that are covered by Title IX, Article 37,
New York Environmental Conservation Law

Note:
- Regulatory requirement is for
accessible materials only or component
which can be accessed after use and
abuse test specifically.
- In lieu of testing, LoG can be accepted
h th d t i NOT b i t t d t

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SUMMARY OF TEST RESULTS FOR

SP - 951 - Costco
Flame Retardant Restrictions Supplemental Protocol
Client Code: Technician: Report Number:
Start Date: Finish Date: Result Reviewed by:

TEST CODE TESTED PROPERTY REQUIREMENT RESULTS COMMENTS

Pass Fail
* New York State For organohalogen flame retardants:
Toxic chemicals in Children - Vendor shall provide a Letter of
Products - Toxic Chemicals Guarantee (LoG) for product without
in Children's Products intentionally added flame retardant(s).
Testing shall be conducted on accessible
(Continued) and inaccessible polyurethane and
polystyrene foam materials and all
upholstery, excluding leather, covering
polyurethane and polystyrene foam
materials. It would be considered as Non
Conformity (or Failure) for not providing a
letter of guarantee OR product is failed for
the chemical requirement.
- Vendor shall provide documentation or a
Bill of Materials (BOM) for identification of
Polyurethane (PU) or Polystyrene (PS)
Foam. Without information provided, all
foam materials and all upholstery,
excluding leather, covering foam materials
will be tested.
- If Letter of Guarantee (LoG) is not
provided, all foams, textiles and plastics
shall be tested. It would be considered as
Non Conformity (or Failure) even if the
submitted sample complies with
requirements.
- Individual testing would be conducted
- Vendor shall be responsible for the
compliance of all other materials.
Maryland * Flame retardant in child Child care product intended for use by
Flame care product - TCEP, children under 3 years of age shall not
Retardants TDCPP contains tris (2-chloroethyl) phosphate
(TCEP) and tris (1, 3–dichloro–2–propyl)
Restriction
phosphate (TDCPP) content in exceed of
(SB 447,
0.1% (1000 mg/kg) of the weight of total
Section 24- content.
306)
"Child care product" means a consumer
product intended for use by children under
3 years of age including baby product, toys,
and car seats.

Note:
- Regulation effective date: June 1, 2021
- Start testing now no matter the effective
date of the regulation.

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 EUROFINS MTS TEST PROTOCOL

SUMMARY OF TEST RESULTS FOR

SP - 951 - Costco
Flame Retardant Restrictions Supplemental Protocol
Client Code: Technician: Report Number:
Start Date: Finish Date: Result Reviewed by:

TEST CODE TESTED PROPERTY REQUIREMENT RESULTS COMMENTS

Pass Fail
Note:
- Compositing is allowed.
​- Actual testing shall be conducted on accessible and inaccessible polyurethane and polystyrene foam materials and all
upholstery, excluding leather, covering polyurethane and polystyrene foam materials.
- Vendors shall provide a letter of guarantee that flame​ ​retardants have not been added. If vendor cannot provide this,
then all foams, textiles and plastics shall be tested. Failure should be issued for not providing LoG.
- Vendors shall provide documentation or a bill of materials for material identification of polyurethane and polystyrene
foams. If they cannot provide this information, all foam materials and all upholstery, excluding leather, covering foam
materials will be tested.
- Composite up to 3 like materials (except metals).
- Individual materials will be analyzed if the composite result exceeds the adjusted limit (regulatory limit divided by the
number of components).
- Vendor shall be responsible for the compliance of all other materials and all other children's products.
Maryland * Flame retardant in juvenile Juvenile product, mattress, upholstered
Flame product, mattress, furniture, or reupholstered furniture, shall
Retardants upholstered furniture, or not contains more than 0.1% of flame-
reupholstered furniture retardant chemicals by mass.
Restriction
(SB 447,
If flame retardants are found during any
Section 24- analytical testing in the Costco Smart
306.1) Screening or normal analytical testing,
failure(s) should be issued for Maryland as
applicable (even if an LoG was previously
received).
Report actual results or include data table
within report.

Note:
- Regulation effective date: June 1, 2021
- Start testing now no matter the effective
date of the regulation.

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 EUROFINS MTS TEST PROTOCOL

SUMMARY OF TEST RESULTS FOR

SP - 951 - Costco
Flame Retardant Restrictions Supplemental Protocol
Client Code: Technician: Report Number:
Start Date: Finish Date: Result Reviewed by:

TEST CODE TESTED PROPERTY REQUIREMENT RESULTS COMMENTS

Pass Fail
Definition:
"Flame-retardant chemical" means a chemical that is used to resist or inhibit the spread of fire or act as a synergist to
chemicals that resist or inhibit the spread of fire, including any chemical for which the term “flame retardant” appears on a
safety data sheet developed in accordance with 29 C.F.R. 1910.1200(G); and 1) Contains one or more halogen elements,
including fluorine, chlorine, bromine, or iodine; 2) Contains one or more carbon elements and one or more phosphorus
elements; 3) Contains one or more carbon elements and one or more nitrogen elements; or 4) is a nanoscale chemical.

"Juvenile product" means a consumer product intended for use by a child under the age of 12 years, including a bassinet,
a booster seat, a changing pad, a children’s nap mat, a floor playmat, a high chair, a high chair pad, an infant bouncer, an
infant carrier, an infant seat, an infant swing, an infant walker, a nursing pad, a nursing pillow, a playpen side pad, a play
yard, a portable hook-on chair, and a stroller.

A “Juvenile product” does not include the following:

1. A product that is not primarily intended for use in the home, including a product that is, or is a component part of, a
motor vehicle, a watercraft, an aircraft, or any other vehicle;
2. A product regulated under 49. C.F.R. Part 571, Federal Motor Vehicle Safety Standards;
3. A consumer electronic product; or
4. A product regulated under section 24-306.

"Reupholstered furniture” means furniture for which the original fabric, padding, decking, barrier material, foam, or other
resilient filling has been replaced and that has not been sold since the time of replacement.

"Upholstered furniture" means furniture that includes filling materials, barrier materials, decking materials, or cover fabrics.

"Mattress" has the same definition as in 16 C.F.R. section 1632.1.

The following products are exempted from section 24-306.1:

(I) An electronic component, or the casing for an electronic component, of a juvenile product, mattress, upholstered
furniture, or reupholstered furniture;
(II) A component of upholstered or reupholstered furniture other than cover fabric, barrier material, resilient filling material,
and decking material;
(III) Thread or fiber when used for stitching mattress components together; or
Note:
- Actual testing shall be conducted on accessible and inaccessible polyurethane and polystyrene foam materials and all
upholstery, excluding leather, covering polyurethane and polystyrene foam materials.
- Vendors shall provide a letter of guarantee that flame retardants have not been added. If vendor cannot provide this,
then all foams, textiles and plastics shall be tested.
- Vendors shall provide documentation or a bill of materials for material identification of polyurethane and polystyrene
foams. If they cannot provide this information, all foam materials and all upholstery, excluding leather, covering foam
materials will be tested.
- Composite up to 3 like materials (except metals).
- Individual materials will be analyzed if the composite result exceeds the adjusted limit (regulatory limit divided by the
number of components).
- Vendor shall be responsible for the compliance of all other materials and all other children's products.

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 EUROFINS MTS TEST PROTOCOL

SUMMARY OF TEST RESULTS FOR

SP - 951 - Costco
Flame Retardant Restrictions Supplemental Protocol
Client Code: Technician: Report Number:
Start Date: Finish Date: Result Reviewed by:

TEST CODE TESTED PROPERTY REQUIREMENT RESULTS COMMENTS

Pass Fail
California AB * Flame Retardant Limit: 1000 mg/kg per each
2998 / Chemicals in Juvenile
Solvent products, Mattresses, or Lab suggest to test the following flame
Upholstered Furniture retardants which are comparatively
Extraction.
commonly found in the products:
Analyzed by
(Effective Date: Jan 01,
GC/MS Flame retardant / CSA#
2020)
1 Tetrabromobisphenol A (TBBPA) 79-94-7
2 Pentabromoethylbenzene (PBEB) 85-22-
3
3 Hexabromobenzene (HBB) 87-82-1
4 Pentabromotoluene (PBT) 87-83-2
5 Melamine 108-78-1
6 Chlorendic acid 115-28-6
7 Triphenyl phosphate (TPP) 115-86-6
8 Tris(2-chloroethyl)phosphate (TCEP) 115-
96-8
9 2,4,6-Tribromophenol 118-79-6
10 Tris(2,3-dibromopropyl) phosphate
(TDBPP) 126-72-7
11 Tri-n-butyl phosphate (TNBP) 126-73-8
12 Pentabromophenol (PBP) 608-71-9
13 Pentachlorobenzene 608-93-5
14 2,4-Dibromophenol 615-58-7
15 Tetrabromophthalic anhydride 632-79-1
16 2-Ethylhexyl diphenyl phosphate
(EHDPP) 1241-94-7
17 Tricresyl phosphate (TCP) 1330-78-5
18 Allyl 2,4,6-tribromophenyl ether (ATE)
3278-89-5
19 2,2-Bis(bromomethyl)-1,3-propanediol
3296-90-0
20 1,2-Dibromo-4-(1,2-
dibromoethyl)cyclohexane
(Tetrabromoethylcyclohexane [TBECH])
3322 93 8

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SUMMARY OF TEST RESULTS FOR

SP - 951 - Costco
Flame Retardant Restrictions Supplemental Protocol
Client Code: Technician: Report Number:
Start Date: Finish Date: Result Reviewed by:

TEST CODE TESTED PROPERTY REQUIREMENT RESULTS COMMENTS

Pass Fail
* Flame Retardant 21 Tetrabromobisphenol A bis(2-
Chemicals in Juvenile hydroxyethyl) ether 4162-45-2
products, Mattresses, or 22 Bisphenol A bis(diphenyl phosphate)
Upholstered furniture 5945-33-5
23 Antimony & Antimony compounds 7440-
(Continued) 36-0
24
Bis(hexachlorocyclopentadieno)cyclooctan
e (Dechlorane Plus (DP)) 13560-89-9
25 Tris(1-chloro-2-propyl)phosphate
(TCPP) 13674-84-5
26 Tris(1,3-dichloro-2-propyl)phosphate
(TDCPP) 13674-87-8
27 Tetrabromobisphenol A bis(2,3-
dibromopropyl) ether (TBBPA-DBPE)
21850-44-2
28 2,3,5,6-Tetrabromo-p-xylene 23488-38-2
29 Hexabromocyclododecane (HBCD)
25637-99-4
30 Bis(2-ethylhexyl) tetrabromophthalate
(TBPH) 26040-51-7
31 Isodecyl diphenyl phosphate 29761-21-5
32 N,N'-Ethylene-
bis(tetrabromophthalimide) 32588-76-4
33 2,3-Dibromopropyl-2.4.6-tribromophenyl
ether (DPTE) 35109-60-5
34 1,2-Bis(2,4,6-tribromophenoxy)ethane
(BTBPE) 37853-59-1
35 Bis(chloromethyl)propane-1,3-diyl
tetrakis-(2-chloroethyl) bis(phosphate) (V6)
38051-10-4
36 Hexachlorocyclopentadienyl-
dibromocyclooctane (HCDBCO) 51936-55-
1
* Flame Retardant 37 Tris(2,3-dibromopropyl) isocyanurate
Chemicals in Juvenile 52434-90-9
products, Mattresses, or 38 t-Butylphenyl diphenyl phosphate
Upholstered furniture (BPDP) 56803-37-3
39 Resorcinol bis(diphenyl phosphate)
(Continued) 57583-54-7
40 Tris(2,3-dichloro-1-propyl)phosphate 78-
43-3
41 Isopropylated triphenyl phosphate
(IPTPP) 68937-41-7
42 Decabromodiphenylethane (DBDPE)
84852-53-9
43 Short-chain chlorinated paraffins 85535-
84-8
44 2-Bromoallyl 2,4,6-tribromophenyl ether
(BATE) 99717-56-3
45 2-Ethylhexyl-2,3,4,5-
tetrabromobenzoate (TBB) 183658-27-7
46 Isobutoxypentabromocyclododecanes
(iBPBCDs) -
47 Octabromotrimethylphenylindane
(OBIND) -
48 Polybrominated biphenyls (PBBs) -
49 Polybrominated diphenyl ethers
(PBDEs) -

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SUMMARY OF TEST RESULTS FOR

SP - 951 - Costco
Flame Retardant Restrictions Supplemental Protocol
Client Code: Technician: Report Number:
Start Date: Finish Date: Result Reviewed by:

TEST CODE TESTED PROPERTY REQUIREMENT RESULTS COMMENTS

Pass Fail
* Flame Retardant Note:
Chemicals in Juvenile ​- Actual testing shall be conducted on
products, Mattresses, or accessible and inaccessible polyurethane
Upholstered furniture and polystyrene foam materials and all
upholstery, excluding leather, covering
(Continued) polyurethane and polystyrene foam
materials.
​- Vendors shall provide a letter of
guarantee that flame​ ​retardants have not
been added. If vendor cannot provide this,
then all foams, textiles and plastics shall be
tested.​ Failure should be issued for not
provided LoG​
- Vendors shall provide documentation or a
bill of materials for material identification of
polyurethane and polystyrene foams. If they
cannot provide this information, all foam
materials and all upholstery, excluding
leather, covering foam materials will be
tested.
- Composite up to 3 like materials (except
metals).
- Individual materials will be analyzed if the
composite result exceeds the adjusted limit
(regulatory limit divided by the number of
components).
- Vendor shall be responsible for the
compliance of all other materials and all
other children's products.
New * Flame retardant in Upholstered furniture shall not contain
Hampshire residential upholstered more than 0.1% of a flame-retardant
Flame furniture chemical or more than 0.1% of a mixture
that includes flame-retardant chemicals.
Retardants
Restriction
If flame retardants are found during any
(Chapter analytical testing in the Costco Smart
336, SB 193- Screening or normal analytical testing,
FN)/ failure(s) should be issued for New
Document Hampshire as applicable (even if an LoG
Review was previously received).
Report actual results or include data table
within report.

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SUMMARY OF TEST RESULTS FOR

SP - 951 - Costco
Flame Retardant Restrictions Supplemental Protocol
Client Code: Technician: Report Number:
Start Date: Finish Date: Result Reviewed by:

TEST CODE TESTED PROPERTY REQUIREMENT RESULTS COMMENTS

Pass Fail
Definition:
"Flame-retardant chemical" means a chemical or chemical compound for which a functional use is to resist or inhibit the
spread of fire. "Flame-retardant chemical" includes, but is not limited to, halogenated, phosphorus-based, nitrogen-based
and nanoscale flame retardants and any chemical or chemical compound for which "flame retardant" appears on the
substance safety data sheet required under 29 C.F.R. section 1910.1200(g).

"Upholstered furniture" means residential furniture intended for indoor use in a home or other dwelling intended for
residential occupancy that consists in whole or in part of resilient cushioning materials enclosed within a covering
consisting of fabric or related materials.

"Mattress" has the same definition as in 16 C.F.R. section 1632.1.

Exemptions:
- Used upholstered furniture, including antique upholstered furniture
- Upholstered furniture purchased for public use in public facilities, including, but not limited to, schools, jails, and
hospitals, that is required by the state or by local fire codes to meet specific flammability standards which cannot be
reasonably be met without the use of flame retardants
- Upholstered furniture which includes electronic or electric components
- Mattresses
- New upholstered furniture that is imported into the state or acquired by the retailer or wholesaler prior to January 1st,
2021; and
- New upholstered furniture that is manufactured prior to January 1st, 2020.

Products that meet the following requirements shall be deemed in compliance with this chapter:
- Upholstered furniture bearing a label or accompanied by a certificate indicating compliance with California BPC section
19101, as amended.
- Upholstered furniture bearing a label, as prescribed by California BPC section 19094 (2014), indicating that the product’s
Note:
- Actual testing shall be conducted on accessible and inaccessible polyurethane and polystyrene foam materials and all
upholstery, excluding leather, covering polyurethane and polystyrene foam materials.
- Vendors shall provide a letter of guarantee that flame retardants have not been added. If vendor cannot provide this,
then all foams, textiles and plastics shall be tested.
- Vendors shall provide documentation or a bill of materials for material identification of polyurethane and polystyrene
foams. If they cannot provide this information, all foam materials and all upholstery, excluding leather, covering foam
materials will be tested.
- Composite up to 3 like materials (except metals).
- Individual materials will be analyzed if the composite result exceeds the adjusted limit (regulatory limit divided by the
number of components).
- Vendor shall be responsible for the compliance of all other materials and all other children's products.

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 EUROFINS MTS TEST PROTOCOL

SUMMARY OF TEST RESULTS FOR

SP - 951 - Costco
Flame Retardant Restrictions Supplemental Protocol
Client Code: Technician: Report Number:
Start Date: Finish Date: Result Reviewed by:

TEST CODE TESTED PROPERTY REQUIREMENT RESULTS COMMENTS

Pass Fail
Washington * Flame retardant 1. All products shall not contain
DC Decabromodiphenyl ether Decabromodiphenyl ether (deca–BDE),
§ 8–108.02. (deca–BDE), Octabromodiphenyl ether (octa–BDE) or
Octabromodiphenyl ether Pentabromodiphenyl ether (penta–BDE).
Prohibitions
(octa–BDE), 2. All products shall not contain more than
on
Pentabromodiphenyl ether 1000 ppm of Tris(2-chloroethyl) phosphate
polybrominat (penta–BDE), Tris(2- (TCEP) , and Tris(1,3-dichloro-2-propyl)
ed diphenyl chloroethyl) phosphate phosphate (TDCPP).
ethers/ § (TCEP) or Tris(1,3-dichloro-2-
8–108.02a. propyl) phosphate (TDCPP) Note :
Prohibitions - Vendor shall provide a Letter of
on (Applicable to all products) Guarantee (LoG) for product without
chlorinated intentionally added flame retardant(s).
flame Testing shall be conducted on accessible
and inaccessible polyurethane and
retardants
polystyrene foam materials and all
upholstery, excluding leather, covering
polyurethane and polystyrene foam
materials. It would be considered as Non
Conformity (or Failure) for not providing
letter of guarantee OR product is failed to
requirement.
- Vendor shall provide documentation or a
Bill of Materials (BOM) for identification of
Polyurethane (PU) or Polystyrene (PS)
Foam. Without information provided, all
foam materials and all upholstery,
excluding leather, covering foam materials
will be tested.
- If Letter of Guarantee (LoG) is not
provided, all foams, textiles and plastics
shall be tested. It would be considered as
Non Conformity (or Failure) even submitted
sample complies with requirement.
- Individual testing would be conducted
Vendor shall be responsible for the
New York * Flame retardant in new - Beginning January 1st, 2024, no person
Assembly upholstered furniture or shall sell or offer for sale any new
Bill A5418B mattress, electronic display upholstered furniture or mattress, that
contains any intentionally added covered
flame retardant chemical, individually or in
combination.

- Beginning January 1st, 2024, no person

shall sell or offer for sale any electronic
display that contains an intentionally added
organohalogen flame retardant chemical in
the enclosure or stand of such electronic
display.

(Costco requirement: effective

immediately)

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SUMMARY OF TEST RESULTS FOR

SP - 951 - Costco
Flame Retardant Restrictions Supplemental Protocol
Client Code: Technician: Report Number:
Start Date: Finish Date: Result Reviewed by:

TEST CODE TESTED PROPERTY REQUIREMENT RESULTS COMMENTS

Pass Fail
Definition:
“covered flame retardant chemical” means any chemical that meets the following criteria:
• A functional use for the chemical is to resist or inhibit the spread of fire or as a synergist to chemicals that resist or inhibit
the spread of fire; and
• The chemical is one of the following: a halogenated, organophosphorus, organonitrogen, or nanoscale chemical.

A “halogenated chemical” is defined as any chemical that contains one or more halogen elements, including fluorine,
chlorine, bromine, or iodine.
An “organophosphorus chemical” is defined as any chemical that contains one or more carbon elements and one or more
phosphorus elements.
An “organonitrogen chemical” is any chemical that contains one or more carbon elements and one or more nitrogen
elements.

"Mattress" means a ticking filled with a resilient material used alone or in combination with other products intended or
promoted for sleeping upon.

"Electronic display" means a consumer product with a display screen and associated electronics that, as its primary
function, displays visual information from wired or wireless sources and is available for purchase by individuals or
households for personal use in a residential space. Electronic display shall not include: (a) any electronic display with a
screen area smaller than or equal to one hundred square centimeters or fifteen and one-half square inches; (b)
projectors; (c) virtual reality headsets; (d) all-in-one video conference systems; or (e) displays that are integrated with
appliances and are not available for purchase as separate products by end-users.

Exemptions:
• Electronic components of mattresses, reupholstered furniture, or upholstered furniture, or any associated casing for
such electronic components.
• Upholstered or reupholstered furniture components other than those identified in subdivision 7 of section 37-1001.
• Thread or fiber when used for stitching mattress components together.
• The natural fibers wool, silk, and other animal fibers whether used singly or in combination with other materials.
• Textiles made using modacrylic fiber components without antimony trioxide when used internally as a barrier material in
a memory foam or gel foam mattress or aramid fibers when used in the fabric that covers the bottom (non-sleep surface)
f
Note: tt th t h l i f l id f th tt Thi ti ill i J 1 t
- Actual testing shall be conducted on accessible and inaccessible polyurethane and polystyrene foam materials and all
upholstery, excluding leather, covering polyurethane and polystyrene foam materials.
- Vendors shall provide a letter of guarantee that flame retardants have not been added. If vendor cannot provide this,
then all foams, textiles and plastics shall be tested.
- Vendors shall provide documentation or a bill of materials for material identification of polyurethane and polystyrene
foams. If they cannot provide this information, all foam materials and all upholstery, excluding leather, covering foam
materials will be tested.
- Vendors shall be responsible for the compliance of all other materials.

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SUMMARY OF TEST RESULTS FOR

SP - 951 - Costco
Flame Retardant Restrictions Supplemental Protocol
Client Code: Technician: Report Number:
Start Date: Finish Date: Result Reviewed by:

TEST CODE TESTED PROPERTY REQUIREMENT RESULTS COMMENTS

Pass Fail
Delaware * Flame retardant in Any component part of children's product
(House Bill children's product and and upholstered furniture shall not contain
No. 77) upholstered furniture more than 0.1% of below flame-retardant
including mattresses chemical or 0.1% of a mixture that includes
1 or more below flame-retardant chemicals:

1.2-ethylhexyl-2,3,4,5-
tetrabromobenzoate (TBB)
2.Antimony
3.Bis(2-ethylhexyl) tetrabromophthalate
(TBPH)
4.Chlorinated paraffins
5.Decabromodiphenyl ether
6.Hexabromocyclododecane
7.Tetrabromobisphenol A (TBBPA)
8.Tris(1,3-dichloro-2-propyl) phosphate
(TDCPP)
9.Tris(2-chloroethyl)phosphate (TCEP)
10.Tris(1-chloro-2-propyl)phosphate
(TCPP)

Mattresses shall not contain 0.1% of an

organohalogen flame retardant or 0.1% of a
mixture that includes 1 or more
organohalogen flame retardants
Definition:
*Children’s product means product designed for residential use by infants and children under 12 years old, including a
bassinet, booster seat, changing pad, floor play mat, highchair pad, infant bouncer, infant carrier, infant seat, infant swing,
infant walker, nursing pad, nursing pillow, playpen side pad, play yard, portable hook-on chair, stroller, mattress, and
children’s nap mat.

*Upholstered furniture means residential furniture intended for indoor use in a home or other dwelling intended for
residential occupancy that consists in whole or in part of resilient cushioning materials enclosed within a covering
consisting of fabric or related materials.

Effective: July 1, 2023

Exemption:
Applied to some used products and electronic components, etc.
https://legis.delaware.gov/json/BillDetail/GenerateHtmlDocumentEngrossment?engrossmentId=24498&docTypeId=6

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SUMMARY OF TEST RESULTS FOR

SP - 951 - Costco
Flame Retardant Restrictions Supplemental Protocol
Client Code: Technician: Report Number:
Start Date: Finish Date: Result Reviewed by:

TEST CODE TESTED PROPERTY REQUIREMENT RESULTS COMMENTS

Pass Fail
Costco Brominated flame retardants USA FD&CA Section 402(a)(2)(C)(i),
Requirement (Applicable to Food contact 801(a)(3).
material)
(For USA only) Food contact materials shall not contain all
chemical brominated flame retardants.

Each brominated flame retardants: Not

Detected.

Note :
- Vendor shall provide a Letter of
Guarantee (LoG) for food-contact materials
without intentionally added brominated
flame retardant(s). It would be considered
as Non-Conformity (or Failure) for not
providing a letter of guarantee.

Flame Retardants List

No. / Chemical Name / CAS No.
1 / 2,4,6-tribromophenol (TBP) / 118-79-
6
2 / 3,3’,5,5’-tetrabromobisphenol A
(HBCD) / 3194-55-6
3 / 1,2,5,6,9,10-hexabromocyclododecane
(TBBPA) / 79-94-7
4 / Decabromodiphenylether (BDE-209) /
1163-19-5
5 / Decabromodiphenylethane (DBDPE) /
84852-53-9

V d h ll b ibl f th
Canada
Canada * Tris-(2-chloroethyl) Prohibited
Consumer phosphate (TCEP)
Product Content Note:
Applicable to PU Foam ​-Actual testing shall be conducted on PU
Safety Act
containing products for Foam containing products for children
(S.C. 2010,
children under the age of 3 under the age of 3
c. 21), (For products entering ​- Vendors shall provide a letter of
Schedule 2 Canada) guarantee that flame​ ​retardants have not
Item 16 been added.
(SOR 2014- (For accessible and - Vendors shall provide documentation or a
79) / inaccessible materials) bill of materials for material identification of
Solvent polyurethane foams. If they cannot provide
Extraction / this information, all foam materials
GCMS materials will be tested.
- Composite up to 3 like materials (except
metals).
- Individual materials will be analyzed if the
composite result exceeds the adjusted limit
(regulatory limit divided by the number of
components).

Latest revision: 7 Sep 2023 Page 25 of 29

 EUROFINS MTS TEST PROTOCOL

SUMMARY OF TEST RESULTS FOR

SP - 951 - Costco
Flame Retardant Restrictions Supplemental Protocol
Client Code: Technician: Report Number:
Start Date: Finish Date: Result Reviewed by:

TEST CODE TESTED PROPERTY REQUIREMENT RESULTS COMMENTS

Pass Fail
Canada * Tris(2,3-dibromopropyl) Prohibited
Consumer Phosphate
Product Note:
Applicable to products made ​-Actual testing shall be conducted on
Safety Act
in whole or in part of textile accessible and inaccessible polyurethane
(S.C. 2010,
fibres, intended for use as and polystyrene foam materials and all
c. 21), wearing apparel. upholstery, excluding leather, covering
Schedule 2 polyurethane and polystyrene foam
Item 10 / (For accessible and materials.
Solvent inaccessible materials) ​- Vendors shall provide a letter of
Extraction / guarantee that flame​ ​retardants have not
GCMS been added. If vendor cannot provide this,
then all foams, textiles and plastics shall be
tested.​ Failure should be issued for not
provided LoG​
- Vendors shall provide documentation or a
bill of materials for material identification of
polyurethane and polystyrene foams. If they
cannot provide this information, all foam
materials and all upholstery, excluding
leather, covering foam materials will be
tested.
- Composite up to 3 like materials (except
metals).
- Individual materials will be analyzed if the
composite result exceeds the adjusted limit
(regulatory limit divided by the number of
components).
- Vendor shall be responsible for the
compliance of all other materials and all
other children's products.

UK / France / Spain / Iceland / Sweden

Commission * Three Flame Retardants On June 20th, 2014, the European
Directive (TCEP, TCPP & TDCP) are Commission issued Commission Directive
2014/79/EU Restricted in EU Toys Safety 2014/79/EU, amending Appendix C of
Directive Annex II to Directive 2009/48/EC of the
(Applicable to plastics and European Parliament and of the Council on
fabric(including foam and the safety of toys, as regards to TCEP,
synthetic leather) TCPP, and TDCP.

1. Toys (accessible parts) Effective Dated: December 21, 2015

intended for use by children
under 36 months Flame Retardant: TCEP / TCPP / TDCP
CAS Number: 115-96-8 / 13674-84-5 /
2. Other toys intended for 11674-87-8
use by children over 36 Requirement(mg/kg): 5 / 5 / 5
months and intended to be
placed in the mouth TCEP(tris(2-chloroethyl) phosphate)
TCPP(tris(2-chloro-1-methylethyl)
TDCP(tris[2-chloro-1-(chloromethyl)ethyl]
phosphate

In lieu of testing, test report dated within

one year can be submitted for review.

Latest revision: 7 Sep 2023 Page 26 of 29

 EUROFINS MTS TEST PROTOCOL

SUMMARY OF TEST RESULTS FOR

SP - 951 - Costco
Flame Retardant Restrictions Supplemental Protocol
Client Code: Technician: Report Number:
Start Date: Finish Date: Result Reviewed by:

TEST CODE TESTED PROPERTY REQUIREMENT RESULTS COMMENTS

Pass Fail
Regulation * Hexabromocyclododecane Products or flame-retarded parts of product
(EU) No (HBCDD) shall contain hexabromocyclododecane
2019/1021 (HBCDD) content in concentrations equal
(For accessible and to or less than 100 mg/kg (0.01% by
and its
inaccessible materials) weight).
amendments
Note:
​- Actual testing shall be conducted on
accessible and inaccessible polyurethane
and polystyrene foam materials and all
upholstery, excluding leather, covering
polyurethane and polystyrene foam
materials.
​- Vendors shall provide a letter of
guarantee that flame​ ​retardants have not
been added. If vendor cannot provide this,
then all foams, textiles and plastics shall be
tested.​ Failure should be issued for not
provided LoG​
- Vendors shall provide documentation or a
bill of materials for material identification of
polyurethane and polystyrene foams. If they
cannot provide this information, all foam
materials and all upholstery, excluding
leather, covering foam materials will be
tested.
- Composite up to 3 like materials (except
metals).
- Individual materials will be analyzed if the
composite result exceeds the adjusted limit
(regulatory limit divided by the number of
components).
- Vendor shall be responsible for the
Regulation * Short Chain Chlorinated Shall linot contain
f ll SCCP
h i l ofd1500
in excess ll
(EU) No Paraffin (SCCP) Content mg/kg (0.15 %) for article, or 10000 mg/kg
2019/1021 (1%) use of substance or preparations in
Suggest materials to test production.
and its
are plastics, rubber, paints
amendments
& coatings, leather, In lieu of testing, approved letter of
adhesives, sealants guarantee (LoG) can be submitted if
Solvent dated within one year. Testing of final
(accessible and
Extraction / inaccessible) product is required if the supplier
GC-ECD/GC- refuses to sign the LoG.
NCI-MS
Note:
If actual test is conducted:
1. Composite up to 3 like materials is
allowed.
2. SVHC evaluation:
a) If a component exceeds 1,000 mg/kg ,
report failure under SVHC line and
inform the supplier they need to update
the SVHC declaration. Attach SVHC
declaration into production report.

Latest revision: 7 Sep 2023 Page 27 of 29

 EUROFINS MTS TEST PROTOCOL

SUMMARY OF TEST RESULTS FOR

SP - 951 - Costco
Flame Retardant Restrictions Supplemental Protocol
Client Code: Technician: Report Number:
Start Date: Finish Date: Result Reviewed by:

TEST CODE TESTED PROPERTY REQUIREMENT RESULTS COMMENTS

Pass Fail
EU REACH * Flame Retardants The following flame retardants are banned
Regulation from use in textile articles intended to come
EC No (For accessible and into contact with skin:
inaccessible materials) Polybrominated Biphenyls (PBBs);
1907/2006
Tris-(aziridinyl-Phosphine Oxide (TEPA);
annex XVII
AND
and its Tris-2,3-Dibromopropyl-Phosphate (TRIS).
amendment
no 4,7,8 and The following flame retardants are banned
45; from use in all products above the limits
Regulation indicated:
(EU) No Octabromodiphenylether (octaBDE) – 0.1%
2019/1021 by weight
and its Tetra, Penta-, Hexa-, Hepta-, Deca-
amendments bromodiphenyl ether Sum ≤ 500 mg/kg

Note:
​- Actual testing shall be conducted on
accessible and inaccessible polyurethane
and polystyrene foam materials and all
upholstery, excluding leather, covering
polyurethane and polystyrene foam
materials.
​- Vendors shall provide a letter of
guarantee that flame​ ​retardants have not
been added. If vendor cannot provide this,
then all foams, textiles and plastics shall be
tested.​ Failure should be issued for not
provided LoG​
- Vendors shall provide documentation or a
bill of materials for material identification of
polyurethane and polystyrene foams. If they
cannot provide this information, all foam
materials and all upholstery, excluding
leather covering foam materials will be
* Flame Retardants - Composite up to 3 like materials (except
metals).
(For accessible and - Individual materials will be analyzed if the
inaccessible materials) composite result exceeds the adjusted limit
(regulatory limit divided by the number of
(Continued) components).
- Vendor shall be responsible for the
compliance of all other materials and all
other children's products.

Korea
KS C IEC * Flame retardant - textile The following flame retardants shall not be
62321 and and bedding items used:
Safety
“Beddings” means the - TDBPP [tri(2,3-dibromopropyl) phosphate;
standard of
product used for sleeping: - PentaBDE [Pentabromodiphenyl ethers;
selfregulator
Such as bedding, pillows, - OctaBDE[Octabromodiphenyl ethers]
y safety blankets,
confirmation sleeping bags, covers,
Annex 4.A sheets, hammocks, carpets
(less than 1 m2), etc.

(For accessible materials)

Latest revision: 7 Sep 2023 Page 28 of 29

 EUROFINS MTS TEST PROTOCOL

SUMMARY OF TEST RESULTS FOR

SP - 951 - Costco
Flame Retardant Restrictions Supplemental Protocol
Client Code: Technician: Report Number:
Start Date: Finish Date: Result Reviewed by:

TEST CODE TESTED PROPERTY REQUIREMENT RESULTS COMMENTS

Pass Fail
IMPORTANT NOTICE: Please review the Actual Products against the updated Requirements/Regulation. Prior to
testing and communicate with clients if additional test required. This protocol is the basic guidelines to follow
and does not replace the content of the standard.
Note: It is the Vendor's responsibility to ensure that the products comply with all local laws,
regulations and ordinances of Countries and States where products will be sold. A Pass Lab test
result does not constitute a certification that a vendor's products meet all legal requirements. It is
the vendor's responsibility to manufacture their items to comply with all applicable laws and in
conformance with the purchase order terms and conditions.
Key:
*Additional Charge For This Test **Mandatory Requirement

Latest revision: 7 Sep 2023 Page 29 of 29