CAL 117 vs. ISO 16840-10: the practical answer
Buyers researching CAL 117 foam requirements are usually trying to work out whether the same test satisfies a wheelchair-seating program too — and it doesn’t always. CAL 117 — formally California Technical Bulletin 117-2013 — sets the smolder-resistance requirements for filling materials, including foam, used in upholstered furniture sold in the United States. ISO 16840-10 is a separate, wheelchair-seating-specific international standard that evaluates resistance to ignition of postural support devices, such as cushions and backs, as they are actually used with a wheelchair. Treat these as complementary reference points tied to specific markets and test methods, not interchangeable substitutes for one another.
Why flammability testing matters specifically for wheelchair seating
Wheelchair users may spend extended periods in continuous contact with a cushion or back support and may not always be able to move away quickly from a smoldering or ignition source. That combination of prolonged contact and reduced mobility is part of why flammability performance for wheelchair seating materials receives dedicated attention beyond general furniture flammability rules, and why a wheelchair-specific test standard exists alongside broader furniture-industry references.
CAL 117 foam requirements: what TB117-2013 actually tests
Scope and origin of the California smolder-resistance standard
TB117-2013, issued by California’s Bureau of Household Goods and Services, shifted the state’s furniture flammability requirement away from an earlier open-flame test method toward a smolder-resistance test focused on the filling material itself — commonly foam. Because California furniture regulation has historically influenced sourcing and labeling practices well beyond the state, TB117-2013 compliance is widely used across the US upholstered furniture and seating industry as a baseline foam flammability reference, including in seating adjacent to the medical mobility category.
What the standard measures
At its core, CAL 117 verifies that a filling material resists smoldering ignition under defined test conditions. It is a material-level test — it evaluates the foam or filling itself, generally independent of the finished product’s full construction.
What ISO 16840-10 actually tests
ISO 16840-10 sits within the broader ISO 16840 wheelchair seating standards series. Part 10 specifically addresses resistance to ignition of postural support devices — cushions and backs used with a wheelchair — prescribing its own requirements and test method distinct from general furniture flammability testing. Because it is written for the wheelchair seating use case specifically, it reflects the product as actually configured and used, rather than treating the filling material in isolation.
Six differences buyers should confirm before specifying a standard
- Which market is driving the requirement — a US retail or institutional buyer may reference CAL 117; a wheelchair or seating manufacturer serving an international market may need ISO 16840-10, both, or neither, depending on the destination market and customer contract.
- What is actually tested — the filling material alone, versus the postural support device as configured for use.
- The ignition source and test method each standard prescribes, which are not the same and are not directly convertible from one to the other.
- The regulatory lineage — a California state technical bulletin with wide informal industry adoption, versus a purpose-built international product standard.
- How results are typically documented — a material test report referencing TB117-2013, versus conformance documentation referencing the ISO 16840 series.
- Whether your specific customer, distributor, or target country actually requires one, the other, both, or neither — this should be confirmed contractually, not assumed from category norms.
Who typically asks for which standard
In practice, the standard a buyer needs usually follows the sales channel rather than the product category alone. A distributor or retailer selling seating or cushions into the US market has historically leaned on TB117-2013-style documentation because of California’s outsized influence on US furniture flammability practice. A wheelchair or mobility-device manufacturer building to an international product specification, or selling into markets that reference the ISO 16840 series directly, is more likely to need ISO 16840-10 conformance documentation for the finished postural support device. Some programs — particularly those selling into multiple markets through different channels — end up needing documentation for both, which is a commercial and cost decision worth raising with your supplier early, not after tooling and materials are already locked in.
What this means for sourcing foam and cushion covers
For companies that outsource manufacturing to Vietnam for wheelchair seating components, flammability documentation is one of the most commonly requested items during supplier qualification — and one of the easiest to get wrong by assuming a single standard covers every market. Confirm with your own regulatory or compliance function which standard, or combination of standards, applies to your target market and distribution channel before finalizing a material specification. Then request the specific test report tied to the actual material lot being used in your product — not a general claim that a material “meets flammability requirements.”
Most cushioning foam sourced through MZ Vietnam’s supply network is selected to meet CAL 117 fire-retardant requirements, and fabric covers for wheelchair cushions, slings, and related components are SGS-tested against relevant performance parameters. This reflects documented material-level testing support rather than a facility-level certification, and the customer remains responsible for confirming which specific standard applies to their product and target market before finalizing a specification.
A short buyer checklist before finalizing a flammability spec
- Confirm the target market and any customer or distributor requirement in writing.
- Request the specific test report tied to your production lot, not a general supplier claim.
- Confirm which body issued the report and which test method it references.
- Keep the report on file alongside the purchase order for that batch.
- Re-test or re-confirm if the material, supplier, or target market changes.
Choosing the right standard, not just a compliant material
A material that passes one flammability test is not automatically suitable for every market or product configuration. The more useful buyer question is not “is this CAL 117 compliant?” in isolation, but “which standard does my specific market and product require, and can I get the matching documentation for this lot?”
If you’re specifying foam or fabric for wheelchair seating and need to confirm which testing requirements apply to your program, LJ Solutions can review your target market and product configuration with you, and MZ Vietnam can confirm the material-level documentation available for the components in question.
References
- International Organization for Standardization. “ISO 16840-10:2021 — Wheelchair seating — Part 10: Resistance to ignition of postural support devices — Requirements and test method.” iso.org, 2021. https://www.iso.org/standard/79159.html
- California Department of Consumer Affairs, Bureau of Household Goods and Services. “Technical Bulletin 117-2013.” bhgs.dca.ca.gov, 2013. https://bhgs.dca.ca.gov/about_us/tb117_2013.pdf
- ComplianceGate. “California Technical Bulletin 117-2013: An Overview.” compliancegate.com, 2025. https://www.compliancegate.com/california-technical-bulletin-117-2013/