About the ADFC
ADFC Labeling Compliance Program
Labeling Compliance Program Standards
Testing and Evaluation
Lodging a Complaint
The Appeals Process
Actions for Non-Compliance
ADFC Labeling Compliance Program
The objective of the Labeling Compliance Program is to ensure that all natural fill bedding products sold in the U.S. are labeled correctly and that the quality of the products meets or exceeds the claims made on the label or packaging.
The ADFC’s Seal of Approval signifies that down and feather products meet all industry standards and are labeled accurately.
Labeling Compliance Program Standards
All sampling, classification and testing of the filling material will be conducted in accordance with International Down and Feather Bureau (IDFB) standards and performed by an IDFB certified testing laboratory. Areas of compliance include down cluster, species identification, fill power, oxygen number, turbidity, fill weight and thread count. Testing for thread count is performed using ASTM Method 3775. All other areas of compliance must be in accordance with industry standards as well as state and federal laws. Please note that meeting the standards set by the ADFC Labeling Compliance Program is not necessarily proof of compliance with existing state or federal laws.
Testing and Evaluation
All tests must be performed by an IDFB certified laboratory.
Several areas of quality may be considered when testing under the Compliance Program. These areas include: down cluster, species (if applicable), fill power, oxygen number, turbidity, fill weight and thread count. The “weighted point system” used in the Compliance Program considers all areas tested and assigns a score to each test result. The overall score is calculated to determine whether a product passes or fails. Tolerances applied in the weighted scoring system are consistent with industry-accepted standards.
Lodging a Complaint
Any ADFC member in good standing may file a complaint with the Standards Testing Committee (STC) for review. To file a complaint with the STC, a member company must submit four test results with an average score that “fails” the Compliance Program weighted scoring guidelines. The four test results must be from an IDFB certified laboratory, and must all come from the same product. If the STC confirms that the four tests submitted do indeed represent a failing score, the STC will purchase, at retail, four more products for testing at the expense of the ADFC. The products must be the same as the original four items submitted, or “like products”, if identical items are not available. The STC will submit these four products to an IDFB certified laboratory for testing. They will be sent exactly as purchased, with the packaging unopened. The results of these four tests will be scored and averaged using the Compliance Program’s weighted scoring system. If the products pass this round of testing, the case will be dismissed. If they fail, the company supplying the products to the marketplace will be informed of the results and offered the opportunity to appeal.
Complaints about representations, claims or advertising will be considered by the ADFC on a case-by-case basis.
Labeling Compliance Program:
Complaint Reporting Form (pdf)
The Appeals Process
Any company that fails testing may appeal the findings. In the event of an appeal, the ADFC program manager will purchase four more samples of the same or similar product and submit them for a third round of testing. The evaluation of the scores from the second and third rounds of testing will be averaged together to determine the final score. The appealing company shall pay for the samples and testing.
Actions for Non-Compliance
In the event that a member company does not comply with the program, that company will be put on probation for the period of one year, removed from the membership roster and be required to pay for additional rounds of testing. If the company refuses the additional testing, refuses to participate in, and fund, the initial testing or the additional rounds of tests, or does not pay dues and their share of ADFC expenses during the probation period they will be expelled from membership. If the company passes the additional rounds of testing they will be taken off probation and all membership rights will be reinstated. Ongoing violations may be reported to the appropriate government agencies
A non-member company that has been found to be in violation of the Labeling Compliance Program will be notified in writing and given the same opportunity to retest and appeal as member companies. If the non-member company refuses to participate in retesting and the violations continue, the non-member shall be notified in writing that failure to comply with standards may result in notification being sent to the appropriate government agencies.
Should a “qualifying” non-member company wish to bring a complaint, they must first become a member of the Home Products Fashion Association, join the American Down and Feather Council, and be subject to the same conditions as other members. Should a “non-qualifying” non-member wish to lodge a complaint, they are required to pay a $5,000 per complaint fee in addition to all other costs associated with bringing a complaint.
There are 24 IDFB Certified Testing Laboratories worldwide, two of which are located in the U.S.:
International Down & Feather Testing Laboratory
The Down & Feather Testing Laboratory