Do you plan to import or manufacture pillows and bedding items in the United States? This guide covers various regulations, flammability standards, chemical restrictions, labeling, and other compliance requirements for bedding and pillow products in the US.
More specifically, the guide covers 16 CFR 1500.18, CPSIA, ASTM standards, Law Labels, and other compliance requirements.
- Bedding sets
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Ban on Infant Cushions and Pillows (16 CFR 1500.18)
16 CFR Part 1500.18 bans several children’s toys and articles as they present mechanical hazards that might injure a child or result in their illness. Part 1500.18(a)(16) specifically bans infant cushions and pillows with characteristics such as the following:
a. The fabric covering is flexible
b. The pillow or cushion is loosely filled with granular material, such as polystyrene beads or pellets
c. The cushion or pillow can easily be flattened
d. The product can conform to an infant’s face or body
e. The cushion or pillow is designed and marketed for use by infants under one year of age
Note that 16 CFR Part 1500.18 is a section under the Federal Hazardous Substances Act (FHSA), which bans the types of infant cushions and pillows listed above for reasons such as these:
a. No voluntary standard covering infant cushions has been adopted or implemented
b. Removing infant cushions from the market might result in significant annual savings, since businesses may avoid potential legal issues
c. Labeling requirements and design or performance standards may not prevent potential hazards
Infant & Children’s Bedding Products: CPSIA
The Consumer Product Safety Improvement Act (CPSIA) establishes safety requirements for products designed for children aged 12 and below. This includes bedding items for infants and children.
Importers and manufacturers can use ASTM standards to evaluate the safety of their products. When CPSIA incorporates those standards by reference, it becomes mandatory for importers and manufacturers to abide by the requirements within.
According to our research, there exist no ASTM standards for infant and children’s bedding products that are incorporated under the CPSIA. However, importers and manufacturers of the aforementioned products can still use voluntary standards such as ASTM F1917 to assess product safety.
Importers and manufacturers of infant and children’s bedding products should ensure that their products conform to the CPSIA’s requirements. They should comply with requirements such as the following:
A CPSC-approved testing company must perform third-party laboratory testing and issue a valid test report on beddings and pillows intended for children. Products should test compliant with relevant requirements before going on sale in the United States.
This report only applies to the specific product being tested, meaning that you must test a sample from the production batch of the product you are importing. Test reports that the supplier provides you for any other beddings and pillows, however similar they may be, are insufficient.
CPSC-approved testing companies are also qualified to guide which ASTM and CPSC rules apply to your beddings and pillows. Some testing companies even provide this as part of a requested quotation at no additional charge.
Importers and manufacturers can use ASTM standards such as the ones listed below to assess the safety and performance of beddings and other covered products.
ASTM F1917 – Standard Consumer Safety Performance Specification for Infant Bedding and Related Accessories
This standard contains performance and labeling requirements, as well as test methods. These may minimize potential hazards to children that might be posed by bedding and related accessories.
It covers products such as the following:
- Fitted sheets
- Dust ruffles
- Covers and drapes for canopies
- Mattress covers
- Diaper stackers
- Fabric wall hangings
- Crib bumpers
- Crib liners
ASTM D4151 – Standard Test Method for Flammability of Blankets
This standard identifies test procedures described in the “Voluntary Blanket Flammability Standard” used by the US blanket industry since 1972. Importers and manufacturers can use these test methods to assess the ignitability and flame propagability of blanket fabrics.
The test method in this standard is for use to assess the fabrics used in electric blankets without the resistance heating wires. This standard addresses factors such as the following about the potential combustibility of fabrics:
- Ease of ignition
- Rapidity of burning
- Intensity of burning
ASTM D6177 – Standard Practice for Determining Emission Profiles of Volatile Organic Chemicals Emitted from Bedding Sets
This standard practice covers the process for calculating the emission profiles of volatile organic compounds (VOCs) from new bedding sets. These profiles are based on emissions testing in environmental chambers.
The measurement of air concentrations in environmental chambers determines the profile of bedding set VOC emissions, which are usually highest in new products.
This standard applies to VOCs and outlines procedures such as the following:
a. Procedures for selecting and handling emission samples
b. Procedures for sampling the emissions
c. Analytical methods for testing the emissions
ASTM D6663 – Standard Specification for Woven and Knitted Comforter and Accessory Products for Institutional and Household Use
This standard contains test methods for assessing specific performance characteristics in products such as the following:
- Woven comforter
- Knit comforter
- Accessory products
ASTM D6663 covers the above products in household and institutional environments but does not cover pillows and window treatments.
Textile, Wool and Fur Acts and Rules (16 CFR Part 300, Part 301, Part 303)
The Federal Trade Commission (FTC) requires importers and manufacturers to abide by the requirements established in the Textile, Wool, and Fur Acts and Rules. They should indicate which materials they use to manufacture their textile, wool, and fur products.
Textile Fiber Products Identification Act (16 CFR Part 303)
The Textile Fiber Products Identification Act provides importers and manufacturers with labeling instructions regarding products consisting of and made with textile fibers.
16 CFR Part 303 covers textile fiber bedding products, such as the following:
It does not cover box springs, box springs, furniture, or mattresses.
Importers and manufacturers are required to label their textile products with information such as the following:
- Company or trade name
- Country of origin
- Fiber content (e.g., “100% Egyptian cotton”)
- Registered identification number
Wool Products Labeling Act (16 CFR Part 300)
The Wool Products Labeling Act provides importers and manufacturers with labeling requirements regarding products that contain wool.
16 CFR Part 300 covers products made of or containing wool, including recycled wool. This might also include blankets and other bedding items.
If the product is made entirely out of one fiber, e.g. wool, with any fiber ornamentation not exceeding 5%, then importers and manufacturers may use labeling such as the following:
- “All Wool – Exclusive of Ornamentation”
- “100% Wool – Exclusive of Ornamentation”
However, if the product contains wool and at least one other fiber, importers and manufacturers must provide descriptors such as the following:
- 65% wool, 35% fur fiber
- 70% wool, 20% fur fiber, 10% angora rabbit
Fur Products Labeling Act (16 CFR Part 301)
The Fur Products Labeling Act provides importers and manufacturers with labeling requirements regarding furs and fur products.
16 CFR Part 301 covers furs and fur products, including fur blankets and other bedding products that might be made of fur.
Part 301.39 specifically exempts products containing fur that are obtained from an animal through hunting or trapping.
Importers and manufacturers should follow labeling requirements such as the following:
a. Labels must be in the English language
b. Words or terms must be fully spelled out; abbreviations or ditto marks are prohibited
c. The name of the applicable animal should be used per the Fur Products Name Guide; animals not listed in the guide should be identified by their true English name
d. Country of origin, preceded by the term ‘fur origin’; e.g., “Dyed China Mink, Fur Origin: China”
e. Name of business
f. Registered identification numbers
g. Disclosure of fur products containing material other than a fur
Law labels are covered by state regulations and, as such, the requirements may differ across the United States. Below we list cover California law label requirements as an example. Keep in mind that the requirements often differ between states.
California Law Labels
The California Bureau of Household Goods and Services (BHGS) published the requirements regarding law labels for different types of products, including bedding products such as the following:
- Mattress pads
- Bed pillows
Types of law labels
Different products may carry different types of law labels in California. Here are some examples:
a. Decorative pillow – Type No. 1 label
b. Mattresses – Type No. 7 label, and for rebuilt mattresses, Type No. 9 label
c. Refurbished or renovated bedding products – Type No. 3 label
d. Bulk filling materials (e.g. batting and pads) for bedding products – Type No. 4 label
e. Bed pillows, comforters, mattress pads – Type No. 6 label
Law label information
The law labels for bedding products Type No. 6 should include information such as the following:
- “UNDER PENALTY OF LAW” statement
- “ALL NEW MATERIAL” header
- Description of filling material
- Finished size, in inches
- A registry number
- Certification statement
- Net weight of filling materials, in pounds and ounces
Additional information may be added to the bottom of the label:
- Name of importer or manufacturer
- Date of delivery
- Federal registry number
- Country of origin or “Made for” marking
Do note that other products may have slightly different law label requirements.
Below we list some additional requirements for products that require a law label in California. The label should:
a. Be attached to articles of bedding products with concealed (or bulk) filling material
b. Include the addition of a care label (for certain bedding products, such as bedspreads, coverlets, and quilts)
c. Be constructed of durable material, 2 inches by 3 inches in size
d. Contain information in the English language
US State Regulations
Several regulations across the US cover products such as bedding and pillows. Below we list two examples. Note that our list is not exhaustive.
AB 2998: Flame Retardant Materials
AB 2998 is a bill enforced by the Bureau of Household Goods and Services (BHGS) of the state of California, which prohibits the sale of juvenile products such as pillows, comforters, and other products that contain flame-retardant (FR) chemicals at levels above 1,000 parts per million (ppm).
Note that “juvenile products” are defined as products designed for residential use by children under 12 years of age.
California Proposition 65
California Proposition 65 is enforced by the state of California to protect consumers from harmful chemicals that cause cancer, birth defects, and other reproductive harm.
This proposition requires California to keep an up-to-date list of carcinogenic or hazardous chemicals. It also requires businesses to inform residents about potential exposures to such chemicals.
California Proposition 65 list contains chemicals that may be used in products such as bedding and pillows:
- Azo colorants and azodyes (e.g. Azobenzene)
- Phthalates (e.g. BBP, DEHP, DBP)
- Flame retardants (e.g. PFOA)
Importers and manufacturers who do not wish to provide labels on their products should have them tested to ensure that the products do not contain restricted substances above safe harbor levels.
Pillows and bedding manufactured outside the United States are generally not designed to comply with US federal and state-level regulations. Overseas manufacturers rely on their customers to provide a list of applicable standards and ready-made label files they can apply directly to the product.
Do not assume that pillow and bedding manufacturers in China, Europe, or India are even aware of pillow and bedding standards and requirements in the United States.
The following regulations do not apply specifically to bedding and pillows. However, they are still relevant as the regulations apply to products in general.
Country of Origin Marking
19 CFR Part 134 requires that every product imported to the US must bear a country of origin marking, indicating the product’s source of origin, conspicuously and indelibly, to the consumers in the US.
- Made in China
- Made in Mexico
- Made in USA
- Made in Portugal
- Made in Turkey
You must create a country of origin file and submit it to your manufacturer before starting mass production. We recommend that you provide a country of origin label file in .ai or .eps formats.
Model Toxics in Packaging Legislation
The Model Toxics in Packaging Legislation restricts the use of some heavy metals and other dangerous substances in packaging materials, dyes, and printing inks in many US states. This includes:
- Chromium IV
To assess if your packaging respects these limitations, you should contact a lab testing company such as SGS, Intertek, or QIMA.
Uniform Packaging and Labeling Regulation (ULPR)
The Uniform Packaging and Labeling Regulation (ULPR) is a state regulation that has been adopted by 45 states in the US. It requires labeling information such as the following:
- Commodity identification
- Importer’s or manufacturer’s name and details
- The package’s net quantity in weight, mass, or numerical count
Bag Suffocation Warning
Amazon sellers are required to add a bag suffocation warning to the poly bags on their products. Some states in the US also require the same from importers and manufacturers.