• Flammable Fabrics Act (FFA) Guide For United States Importers

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    The Flammable Fabrics Act (FFA) regulates flammability in clothing, sleepwear, carpets, mattresses, and many other textile products – either manufactured in or manufactured to the United States. In this guide, we explain how the FFA works and what you must do to ensure compliance.

    Product Scope

    The Flammable Fabrics Act broadly covers the following product categories:

    The CPSC has established flammability standards and testing requirements codified in the FFA, for each product category.

    Clothing Textiles and Vinyl Plastic Film for Apparel

    Product Scope

    16 CFR Part 1610 and 1611 establish flammability testing standards and methods for general apparel made of cotton, vinyl plastic film, and other fabrics.

    Standards/Requirements

    16 CFR Part 1610 – Standard for the Flammability of Clothing Textiles

    16 CFR Part 1610 Standard for the Flammability of Clothing Textiles is a standard codified into the Flammable Fabrics Act (FFA) supervised by the Consumer Product Safety Commission (CPSC).

    The standard establishes flammability requirements for textile products that are intended to be worn as clothing, with the exception of hats, gloves shorter than 14 inches, footwear, and interlining fabrics.

    The standard establishes the flammability testing standards, methods, performance requirements, and classification of textile clothing products. Textiles of highly burning properties are not supposed to be made into clothing.

    Finally, note that 16 CFR Part 1610 does not apply to Class I fabrics, which includes:

    a. Plain surface fabrics, regardless of fiber content, with a weight of at least 2.6 ounces per square yard

    b. Any fabric made of acrylic, modacrylic, nylon, olefin, polyester, and wool; or any combination of the above-mentioned fibers. This applies to any kind of fabric weight or surface

    16 CFR Part 1611 – Standard for the Flammability of Vinyl Plastic Film

    16 CFR 1611 Standard for the Flammability of Vinyl Plastic Film establishes the flammability testing standards for garments or products that are made of non-rigid, unsupported vinyl plastic film, such as disposable diapers, raincoats, and socks.

    Labeling Requirements

    16 CFR Part 1610 mandates that for some fabric that is at high risk of flammability, a warning label as the following shall be attached to a product in a clear and legible manner:

    “Fabric may be dangerously flammable if dry cleaned or washed.”

    Children’s Sleepwear

    Product Scope

    16 CFR Part 1615 and 1616 establish flammability testing standards and methods for children’s sleepwear products, including pajamas, robes, nightgowns, and other equivalent products intended to be worn during sleep activity in sizes 0-14.

    Standards/Requirements

    16 CFR Part 1615 – Standard for the Flammability of Children’s Sleepwear: Sizes 0 Through 6X

    16 CFR Part 1615 is a standard concerning the flammability of children’s sleepwear, involving products like pajamas, robes, and nightgowns in sizes 0-6X.

    This standard sets up testing methods and procedures for the products’ fabric, using small open-flame ignition sources, such as stoves, matches, lighters, candles, and space heaters.

    The standard also requires that children’s sleepwear should stop burning when the flame source is removed.

    To determine the correct size of your children’s sleepwear products, you can refer to this size chart.

    16 CFR Part 1616 – Standard for the Flammability of Children’s Sleepwear: Sizes 7 Through 14

    Children’s sleepwear of sizes 7-14 is regulated by the 16 CFR Part 1616 with respect to flammability and safety issues.

    Labeling Requirements

    16 CFR Part 1615 and 1616 require that the following information should be displayed on children’s sleepwear’s labels:

    a. Fabric production unit (FPU) identification number (at least 0.4 centimeters in height)

    b. Garment production unit (GPU) identification number (at least 1.3 X 1.9 centimeters)

    c. Care labels

    Carpets and Rugs

    Product Scope

    16 CFR Part 1630 and 1631 are two standards regulating the flammability properties of most of the carpets and rug products in the US.

    Such products of certain dimensions, as well as antique or hide carpets are not regulated by these standards.

    Standards/Requirements

    16 CFR Part 1630 – Standard for the Surface Flammability of Carpets and Rugs

    16 CFR Part 1630 Standard for the Surface Flammability of Carpets and Rugs establishes testing methods to determine the surface flammability of carpets and rugs when encountering small sources of ignition, such as cigarette flame or fireplace flame.

    The standard regulates most domestic use carpet products with one dimension greater than 1.83 meters and a surface area greater than 2.23 square meters.

    16 CFR Part 1631 – Standard for the Surface Flammability of Small Carpets and Rugs

    16 CFR Part 1631 established flammability and testing procedures for carpets and rugs that have no dimension greater than 1.83 meters and an area not greater than 2.23 square meters.

    Labeling Requirements

    16 CFR Part 1630 and 1631 require the regulated carpets and rugs that do not meet all the necessary requirements should include a legibly and permanently label with this statement in bold:

    “FLAMMABLE (FAILS U.S. DEPARTMENT OF COMMERCE STANDARD FF 2-70): SHOULD NOT BE USED NEAR SOURCES OF IGNITION”

    Also, if a small carpet or rug has undergone special fire retardant treatment, it shall be labeled with the letter “T”.

    Mattresses

    Product Scope

    16 CFR Part 1632 and 1633 establish flammability requirements for mattresses, mattress pads, and mattress sets, for both smoldering ignition sources and open flame.

    Standards/Requirements

    16 CFR Part 1632 – Standard for the Flammability of Mattresses and Mattress Pads

    16 CFR Part 1632 – Standard for the Flammability of Mattresses and Mattress Pads establishes flammability testing materials, equipment methods, and performance requirements for mattresses and pads when exposed to smoldering ignition sources such as lighted cigarettes and matches.

    16 CFR Part 1633 – Standard for the Flammability (Open Flame) of Mattress Sets

    16 CFR Part 1633 – Standard for the Flammability (Open Flame) of Mattress Sets is a standard that applies to mattress sets, which shall include mattress without foundation.

    The standard establishes flammability requirements and testing procedures for mattress sets in order to decrease incidents and injuries caused by mattress fires.

    Labeling

    Part 1632’s labeling requirements for mattresses and mattress pads are as following:

    a. Mattress pads that contain chemical fire retardants material shall be prominently labeled with the letter “T”.

    b. Pads that are treated with fire retardant shall be labeled with precautionary instructions to protect the fire-retardant materials from damaging

    Labels of mattresses and pads should also disclose information like the month and year of manufacture and the location of the manufacturer.

    Part 1633 specifies labeling requirements for mattress sets, which shall include a legible label(s) containing the following information in English:

    • Business information (name, company address of the manufacturer and importer)
    • Date of manufacture (year and month)
    • Model identification number
    • A certification or test report proving the compliance of the mattress sets

    The standard also requires to display one of the following labels, according to the circumstances:

    “THIS MATTRESS IS INTENDED TO BE USED WITHOUT A FOUNDATION.”

    “THIS MATTRESS IS INTENDED TO BE USED WITH FOUNDATION(S).”

    “THIS MATTRESS IS INTENDED TO BE USED WITHOUT A FOUNDATION OR WITH FOUNDATION(S)”

    Documentation

    General Certificate of Conformity (GCC)

    The General Certificate Conformity (GCC) is a document demonstrating the safety and compliance of the general consumer products, excluding children’s products, drafted either by the importer or the manufacturer.

    Here a list of information that should be displayed in the document:

    • Product identity (model number, name)
    • Safety standards for the product is being certified (ie. 16 CFR Part 1630)
    • Identification and contact information of the importer or domestic manufacturer
    • Date and place of production
    • CPSC-accredited testing agency

    Here are some products covered by the FFA that may require a GCC:

    • Clothing
    • Carpets
    • Mattresses

    Test Report

    Lab test reports correspond with one or more testing FFA related testing standards. Obtaining a lab test report is necessary when importing and sell products covered by the FFA in the United States.

    Lab Testing

    FFA related lab testing services are offered by several companies – both in the United States and in Asia. Here are some companies offering FFA testing services:

    • QIMA
    • Underwriters Laboratories
    • SGS
    • TÜV Rheinland

    Further, note that all of the listed companies are on the list of CPSC accepted testing companies.


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