• Children’s Clothing Regulations in the United States: A Complete Guide

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    Children’s Clothing Regulations in the United States

    Ready to import and sell children’s clothing in the United States? In this article, we cover the relevant children’s clothing regulations, including labeling, certification, and testing requirements.

    Mentioned Products

    • Babywear
    • Nightwear
    • Romper
    • Children’s apparel

    CPSIA

    CPSIA regulates all children’s products, including children’s clothing sold in the United States. The US Consumer Product Safety Commission (CPSC) has defined children’s products as any “ consumer products designed or intended primarily for children 12 years of age or younger”.

    Here an overview of the CPSIA requirements:

    ASTM Standards

    CPSIA requires that your children’s clothing is fully compliant with all applicable ASTM standards, substance restrictions and other rules. Some standards, rules and substance restrictions only apply to specific types of children’s products, while others apply broadly to all children’s products.

    Examples

    • 16 CFR Part 1615, Standard for the Flammability of Children’s Sleepwear
    • 16 CFR Part 1616, Standard for the Flammability of Children’s Sleepwear
    • CPSIA Section 101-Children’s Products-Total Lead (Pb) Content

    Learn more

    You can learn more about relevant ASTM standards and rules on this page.

    CPSIA Testing

    Third-party lab testing for children’s clothing is mandatory and verifies if your children’s apparel or babywear are compliant with applicable ASTM standards and substance restrictions. You can only carry out the third-party lab testing using CPSC approved testing companies. Otherwise, the test report is not valid for compliance purposes.

    Some suppliers might provide a CPSIA test report for children’s products that are similar to the ones you want to import.

    However, a test report is only valid for the very same products that you are importing to the United States. That means you must collect the sample from the production batch and submit it to the laboratory for testing.

    Testing companies can also help to determine if there are other applicable standards, such as ASTM and CPSC. Most of the testing companies usually provide this service for free.

    List CPSC approved testing companies

    • Eurofins
    • CMA Testing
    • UL
    • SGS
    • QIMA

    Click here for a more comprehensive list of CPSC approved testing companies.

    CPSIA Testing Costs

    The cost depends on applicable standards, materials, and colors. In general, it starts at around $300 per children’s clothing style. That said, this cost increases significantly if your children’s clothing is made of several fabrics, colors, buttons, zippers, velcro, and other material.

    As such, the best way to keep costs down is by reducing the number of different fabrics, colors, and components. For example, you can save on testing fees by using the same fabrics, colors, zippers and buttons on many different products.

    Learn more

    Find more information about CPSIA and ASTM standards in this guide.

    Children’s Product Certificate (CPC)

    Importers must issue a CPC for their children’s clothing products, to certify that the children’s clothing complies with all applicable ASTM and CPSIA standards (e.g. substance restrictions). The CPC is a self-issued document with information such as product name, supplier information, relevant standards, and testing result.

    Content Summary

    1. Product name and description

    2. List of applied and mandatory ASTM and CPSC standards

    3. Importer information (name, address, e-mail address, phone number)

    4. Contact information of the person with access to the test report (name, address, e-mail address, phone number)

    5. Manufacturing location (city, province, country) and date (month, year)

    6. Testing date (month, year) and location (city, province, country)

    7. CPSC accepted third-party lab testing company (company, contact person, address, phone, email)

    Learn more

    Read this guide for more information about CPC when importing children’s clothing.

    CPSIA Tracking Label

    You must prepare a CPSIA tracking label for your children’s clothing. Here is an overview of the required information on the label:

    • Importer company name
    • Production location
    • Production date
    • Batch number

    Example

    • Happy Baby Wear LLC
    • Production Location: Hanoi, Vietnam
    • Production Date: November 2020
    • Batch Number: SKU01-112020-HN-VN

    Label file

    The supplier expects the buyer to provide a ready-made label file. In addition to the tracking label, you must also provide the following information:

    • Print position
    • Dimensions
    • Colors
    • Print type

    Textiles Labeling

    According to FTC labeling requirements, clothing and textile products must be correctly labeled to inform customers of the fiber composition and care instruction. This requirement also includes children’s clothing. Note that the textiles label is required in addition to the CPSIA tracking label.

    Label Information

    • Importer or manufacturer information
    • Fiber composition (e.g. 100% cotton)
    • ASTM care labels (Link)
    • English language

    Label file

    Manufacturers will not create the label for your products as well. You must create the label files in .ai or .eps formats and send it to your manufacturer before the mass production starts.

    Flammable Fabrics Act (FFA)

    The FFA is a standard for the flammability of clothing textiles, also known as the 16 CFR Part 1610.

    It applies to certain kinds of clothing and textile products in the United States, and it is not mandatory for some apparel.

    Fabric Classification

    16 CFR Part 1610 does not apply to Class I fabrics, which are defined as the following:

    a. Plain surface fabrics, regardless of fiber content, with a weight of 2.6 ounces per square yard (Approx 88.2 grams per square meter).

    b. Any fabric made of the following fibers: acrylic, modacrylic, nylon, olefin, polyester, and wool; or any combination of the above-mentioned fibers. This exemption is valid regardless of the surface (i.e., plain or raised-fibers) and the fabric weight.

    FFA Testing

    If you are unsure whether the FFA is applicable to your fabrics, we recommend that you submit fabric samples for third-party FFA testing.

    California Proposition 65

    California Proposition 65 regulates more than 800 toxic substances in all products sold in California, as they are deemed to cause cancer, congenital disabilities, or other reproductive harm. California Proposition 65 also covers children’s clothing. As such, children’s clothing that contains above-limited substances cannot be sold in California.

    Examples of restricted substances

    • Lead
    • Cadmium
    • Formamide
    • Hydrazine

    Warning Labeling

    You can avoid the warning label by verifying California Proposition 65 compliance through third-party testing. Otherwise, if you are not sure that your children’s apparel doesn’t contain an excessive amount of restricted substances, you must attach a warning label to the product or its packaging.

    California Proposition 65 Lab testing

    The restricted substances’ list is updated on a non-regular basis, and most children’s clothing manufacturers in Asia cannot provide California Proposition 65 test reports.

    Therefore, third-party lab testing is the only way to verify the number of regulated substances in your product. We recommend that you book a lab test for your children’s clothing product before shipping them to the United States.

    Testing costs

    In general, the testing cost starts at $200, and it can increase depending on the number of styles, materials, components (e.g. buttons and zippesrs) and colors.

    Testing companies

    Click here to see a list of California Proposition 65 lab testing companies.

    Country of Origin

    The country of origin marking is mandatory for most products sold in the United States. This requirement also covers children’s clothing. The country of origin marking must be permanently affixed to the product and its packaging.

    Examples

    • Made in Japan
    • Made in China
    • Made in Vietnam
    • Made in Bangladesh
    • Made in India
    • Made in Germany
    • Made in France

    Label file

    You can’t expect your manufacturer to create a country of origin label for your product. You must create the label files in .ai or .eps formats, then submit it to your manufacturer before mass production.

    Amazon Children’s Clothing Requirements

    You will need to obtain approval from Amazon before start selling children’s clothing in their platform. As such, your products must comply with all mandatory standards, regulations, certifications, and labeling requirements. Sellers also need to provide the CPC, ASTM test report, and other relevant documents before they can start selling.

    You should read the relevant product category requirements carefully in the Amazon Seller Central before you import and sell children’s clothing on Amazon.com.

    How does Amazon check product compliance?

    Amazon might request several documents, including lab test reports, CPC, product photos, or invoices of your products at any time.

    Amazon has the right to review your children’s clothing products for compliance checking purposes. They often reject sellers that cannot provide the required documents.

    What can happen if we sell non-compliant children’s clothing on Amazon?

    Amazon can remove your product listing from Amazon.com and suspend your account if needed. Note that Amazon often limits its actions to specific SKUs, even though they can also decide to suspend your whole account.


  • Important Notice: Articles, videos and other content on this website are provided for educational purposes only. The content contains only general information about product safety, labeling, documentation, testing, risks, and other product compliance-related topics. It is not legal advice, and should not be treated as such. Further, we don't guarantee that the information provided in this article is up to date, all-encompassing or accurate. Also, we generally don't cover European national and US state standards/regulations/requirements.

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