Carpets and rugs sold in the United States are subject to various regulations, flammability standards, labeling, and testing requirements. In this guide, we cover the Flammable Fabrics Act, CPSIA, ATSM standards, California Proposition 65, and other compliance requirements for carpets and rugs.
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Flammable Fabrics Act
The Flammable Fabrics Act (FFA) enables the Consumer Product Safety Commission (CPSC) to enact flammability standards for which compliance is mandatory. These standards generally cover fabrics used in or with products and materials such as clothing textiles, carpets and rugs, children’s sleepwear, and mattresses.
16 CFR Part 1630 – Standard for the Surface Flammability of Carpets and Rugs (FF 1-70)
16 CFR Part 1630 is a standard that details the method for testing how flammable the surface of carpets and rugs are. More specifically, 16 CFR Part 1630 covers products that have a length of over 6 ft and a surface area of over 24 sq ft.
This standard states that the following one-of-a-kind carpets or rugs may be exempt from testing per the CPSC’s conditions:
The standard requires the usage of the following equipment:
- Flattening frame
- Standard igniting source
- Test specimens
- Circulating air oven
- Desiccating cabinet
- Vacuum cleaner
Each of the eight 9 x 9-inch carpet or rug samples is secured onto a steel plate with a circular hole in the middle, under which is an ignition source. If at least seven of the eight specimens have a charred area that does not reach within 1 inch of the hole’s edge, it means that the carpet or rug has passed testing and can be used safely.
The carpet or rug must be labeled with the letter “T” if the following conditions apply:
a. The product has undergone fire retardant treatment
b. The product consists of fibers that have undergone fire-retardant treatment
16 CFR Part 1631- Standard for the Surface Flammability of Small Carpets and Rugs (FF 2-70)
16 CFR Part 1631 is a standard that provides a method for testing the flammability of the surface of small carpets and rugs.
Part 1631 covers small carpets and rugs that have dimensions that are less than 6 ft and an area of less than 24 sq. ft.
Part 1631 mandates the use of the same apparatus utilized in Part 1630, including eight 9 x 9-inch carpet or rug samples. These samples undergo the same testing requirements as those in Part 1630; if seven of the eight samples pass testing, the small carpet or rug is deemed to comply with the requirements of this standard.
If at least 7 out of the 8 tested carpet or rug samples mentioned above do not comply with the requirements in the standard, it is mandatory that before its sale, the small carpet or rug must be permanently labeled with the following statement:
FLAMMABLE (FAILS U.S. DEPARTMENT OF COMMERCE STANDARD FF 2-70): SHOULD NOT BE USED NEAR SOURCES OF IGNITION.
As with Part 1630, small carpets or rugs under Part 1631 must carry the letter “T” if the product, or the fibers within, have undergone fire retardant treatment.
General Certificate of Conformity (GCC)
A General Certificate of Conformity (GCC) is a self-issued document that importers or manufacturers of products not meant for children might need to provide that states their products’ compliance with relevant standards and regulations.
A GCC is required for a wide range of product categories, including carpets and rugs that fall under the scope of:
- 16 CFR Part 1630
- 16 CFR Part 1631
Importers and manufacturers are required to provide the following information on their GCC:
a. Name and description of the product
b. List of applicable ASTM standards and CPSC safety rules
c. Company name
d. Contact details (email and mailing address, phone number)
e. Name of the person responsible for maintaining the test report
f. Date (month, year) and place (city, country) of production and product testing
g. Contact details of the third-party testing company (name, contact person, email, phone number, address)
The Consumer Product Safety Improvement Act (CPSIA) applies to children’s products imported, manufactured, and sold in the United States. This includes products such as carpets and rugs that are designed and intended for use by children aged 12 and under.
Carpets and rugs designed for children aged 12 and under must meet requirements such as the following:
a. Surface coating limit: any paint used on such products must not contain more than 0.009% lead
b. Lead content limit: carpets and rugs intended for children must not contain lead that exceeds 100 ppm of total lead content
c. Certification: importers and manufacturers must provide a Children’s Product Certificate (CPC) for carpets and rugs meant for children aged 12 and under
d. Tracking label: carpets and rugs designed for children aged 12 and under must carry a tracking label that contains information concerning their company, date of manufacture, and batch number
e. Test report demonstrating compliance with relevant requirements and standards
Textile and Fur Acts and Rules (Part 301 and Part 303)
The Federal Trade Commission (FTC) sets requirements that mandate manufacturers to abide by the Fur Rules and the Textile Fiber Rule when labeling fur and textile products.
16 CFR Part 301 – Fur Products Labeling Act
16 CFR Part 301 provides instructions on how to label fur products.
Part 301 covers fur products, including carpets, mats, and rugs containing fur, except the following:
a. Fur products containing fur from a trapped or hunted animal
b. Fur products sold by a trapper or hunter in a face-to-face transaction at places including residences, craft fairs, or other short-term location
Importers and manufacturers are required to label furs and fur products, such as carpets, rugs, and mats, according to stipulations in Part 301.
The label should include information such as the name of the animal from which the fur originated, the manufacturer’s name, and the country of origin.
Importers and manufacturers may also provide a form of separate guarantee that may read as follows:
“We guarantee that the fur products or furs specified herein are not misbranded nor falsely nor deceptively advertised or invoiced under the provisions of the Fur Products Labeling Act and rules and regulations thereunder.”
16 CFR Part 303 – Textile Fiber Products Identification Act
16 CFR Part 303 provides instructions on labeling products made from and containing textile fibers.
Part 303 covers floor-covering products such as the following:
Importers and manufacturers of floor coverings are required to disclose the fiber content of their products, in a manner such as the following:
- 90% Cotton Pile
- Face – 70% Rayon, 30% Cotton
- Outer Surface – 80% Wool
Textile floor coverings sold in the US must bear labels that disclose the following:
a. The product’s generic name
b. The product’s percentage by weight of constituent fibers
c. Name of the manufacturer
d. Country of origin
Guides for Select Leather and Imitation Leather Products (16 CFR Part 24)
16 CFR Part 24 applies to leather products, including leather carpets.
The guides outline the unfairness of deceiving the consumer as to the product’s overall description, such as its material content, durability, and manufacture. For example, a leather carpet cannot carry the term “warp-proof” unless the entire product, or part of it, cannot be warped.
The FTC may require rectification if, following an investigation, the Commission has reason to believe an unlawful contravention of the Guides has taken place.
Importers and manufacturers are required to provide the necessary disclosures on any of the following:
- Stamp on the product
- Tag or label on the product
- Card attached to the product
- Advertisement of the product
Disclosures should include information such as the following:
- Material content
- Country of origin
- Manufacturer’s identity
- Care instruction
ASTM standards are generally voluntary. Yet, it is recommended to follow these standards to assess a product’s safety and performance, for instance.
Compliance with some ASTM standards becomes mandatory when said standards have been incorporated by reference into regulations such as the CPSIA.
ASTM standards applicable to carpets and rugs include the following examples:
a. ASTM D2859-16 – Standard Test Method for Ignition Characteristics of Finished Textile Floor Covering Materials
b. ASTM D7983-17 – Standard Test Method for Shrinkage of Carpet Backing Fabrics
c. ASTM E2966-14 – Standard Test Method for Quantitative Assessment of Sanitizing Solutions for Carpet
d. ASTM F2828-20 – Standard Test Method for Assessing Carpet Cleaning Effectiveness in Terms of Visual Appearance Change When Cleaned with a Wet Extraction Cleaning System
The United States Environmental Protection Agency (EPA) recommends the use of approved private sector standards/ecolabels. This includes the following:
a. NSF/ANSI 140 – Sustainability Assessment for Carpet
b. UL 2818 GREENGUARD Certification Program For Chemical Emissions For Building Materials, Finishes And Furnishings
c. BioPreferred® Program – USDA Certified Biobased
The NSF/ANSI 140 standard is used to certify and evaluate the sustainability of commercial carpet products across their product life cycle. Importers and manufacturers benefit from this certification by:
- Having an enhanced brand
- Obtaining a preferred vendor status
- Achieving high levels of credibility
UL 2818 GREENGUARD Certification Program
The UL 2818 program standard is used to determine the organic chemical emissions from building materials, finishes, and furnishings, such as carpets.
If products achieve the UL Greenguard Certification, sellers can use said certification to reassure their customers that their products meet or exceed industry standards for low emissions. Sellers of UL Greenguard Gold Certified products, especially those for schools or children’s rooms, can reassure their customers that their products are safer because they meet even stricter and lower emission standards.
USDA’s BioPreferred® Program helps importers and manufacturers to identify products that qualify for either, or both, of the following:
- Mandatory federal purchasing
- Voluntary labeling initiative
Sellers of products, such as carpets, bearing the USDA Certified Biobased Product label can communicate to their customers that the USDA approves the accuracy of the percentage of biobased ingredients as stated on the label.
If a product meets or exceeds the minimum biobased content requirements for at least one USDA-identified product category, then it qualifies for federal purchasing, which means that federal agencies can purchase such products.
The following regulations are not applicable specifically to carpets and rugs. However, they are still relevant as the regulations are applicable to products in general.
Country of Origin Marking
The country of origin marking (e.g. Made in Vietnam) is mandatory in the United States and applies to most products. This includes textiles such as carpets and rugs.
Additionally, the FTC requires products carrying the “Made in the USA” label to be completely manufactured in the United States, and importers and manufacturers to provide reliable evidence that their products (eg., carpets and rugs) have been entirely produced within the US.
The “Made in USA” label may be expressed in different forms, such as the following:
- “Made in USA”
- “Our products are American-made”
California Proposition 65
Proposition 65 is officially known as the Safe Drinking Water and Toxic Enforcement Act of 1986 and is administered by the California Office of Environmental Health Hazard Assessment (OEHHA). The Proposition prohibits the following:
a. The unlimited usage, without relevant warnings, of toxic chemicals in consumer products
b. The discharge of listed substances into sources of drinking water.
Proposition 65 regulates certain chemicals that may require businesses in California to provide “clear and reasonable” warnings. Failure to do so, or violating any part of Proposition 65, results in penalties of up to US$2,500 per violation, per day.