Planning to manufacture, import, or sell clothing or other textiles in the United States? In this guide, we explain what you must know about chemical and heavy metals regulations, labeling requirements, lab testing, certification, and much more concerning textiles compliance in the United States.
Flammable Fabrics Act (FFA)
The Flammable Fabrics Act (FFA), administered by the Consumer Product Safety Commission (CPSC), is an act that concerns the flammability of clothing, fabrics, carpets, and other textile products manufactured or sold in the United States. It has established flammability standards for clothing textiles, vinyl plastic film, children’s sleepwear, and other types of fabric products.
Part 1610 – Standard for the Flammability of Clothing Textiles
16 CFR Part 1610 Standard for the Flammability of Clothing Textiles is a standard that is incorporated into the FFA. It set out rules and requirements for clothing and apparel that are made of fabrics.
This standard sets up rules regarding the flammability testing standards, methods, performance requirements, and classification of textile clothing products. It requires that textiles that have high flammability shall not be made into clothing.
16 CFR Part 1610 applies to fabrics that are intended to be made into clothing, excluding the following:
a. Class 1 plain surface fabrics with a weight of at least 2.6 ounces per square yard
b. Fabric made of acrylic, modacrylic, nylon, olefin, polyester, and wool (or any combination of the mentioned fibers)
c. Gloves, hats, or footwear that don’t cover parts of the body
16 CFR Part 1610 sets forth flammability classification and requirements:
a. Class 1 – Normal flammability: Fabrics are classified as Class 1 if exhibit “normal flammability” after being tested according to the testing methods specified in section 1610.6.
In order to exhibit “normal flammability”, plain surface textile fabric should burn in 3.5 seconds or more, and raised surface textile fabric (textile fabrics that have intentionally raised fiber or yarn surfaces such as a pile, nap, or tufting) should burn in more than 7 seconds. Class 1 fabrics are deemed suitable for clothing.
b. Class 2 – Intermediate flammability: Raised-fiber surface textiles are classified as Class 2 if they exhibit “intermediate flammability” (ie. burn time is from 4 to 7 seconds). In this case, they are still deemed to be suitable to be used as clothing. Note that Class 2 doesn’t apply to plain surface textile fabric.
c. Class 3 – Rapid and intense burning: Class 3 fabrics exhibit “rapid and intense burning”, they are deemed dangerously flammable and should not be used for clothing.
Part 1611- Standard for the Flammability of Vinyl Plastic Film
16 CFR 1611 Standard for the Flammability of Vinyl Plastic Film sets out flammability testing standards and procedures for clothing or textile products that are made of non-rigid, unsupported vinyl plastic film, such as raincoats, and socks.
16 CFR 1611 covers textile products that are made from vinyl plastic film. Examples of such products include:
- Down jackets
- Disposable diapers
This standard requires that fabrics made from vinyl plastic film must fulfill the flammability requirements set forth in the chapter.
For example, Class 1 Plain Surface Textile Fabric should burn in 3.5 seconds or more.
Part 1615 and Part 1616 – Standard for the Flammability of Children’s Sleepwear
16 CFR Part 1615 and Part 1616 are standards concerning the flammability of children’s sleepwear. These two standards set up fabric testing methods and procedures using small open-flame ignition sources, such as stoves, matches, lighters, and candles.
Part 1615 applies to children’s sleepwear in sizes 0-6X, whereas Part 1616 applies to children’s sleepwear in sizes 7-14. This includes:
Part 1615 and 1616 set up testing and labeling requirements for covered products. The following information should be displayed on children’s sleepwear labels:
- Fabric production unit (FPU) identification number
- Garment production unit (GPU) identification number
- Care labels
Part 1630 and Part 1631- Standard for the Surface Flammability of Carpets and Rugs
16 CFR Part 1630 and Part 1631 are two flammability standards for carpets and rugs. They cover testing methods and procedures to determine the surface flammability of carpets and rugs under the circumstances of ignition, such as cigarette flame or fireplace flame.
The requirements of Part 1630 apply to carpet products used in households in dimensions greater than 1.83 meters and a surface area greater than 2.23 square meters.
The requirements of Part 1631 apply to carpets and rugs smaller than the product dimension specified in Part 1630.
16 CFR Part 1630 and 1631 require the carpets and rugs that do not meet all the necessary flammability requirements shall be affixed with a permanent 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”
In addition, a carpet or rug that has gone through special fire retardant treatment should contain the letter “T” on the label.
General Certificate of Conformity (GCC)
The General Certificate Conformity (GCC) is a document that is self-issued by importers or manufacturers of non-children’s products to demonstrate that the products have been tested according to the applicable CPSC’s safety standards or regulations and that such products comply with the technical and regulatory requirements.
A GCC should include information such as:
a. Product description (product name, model/batch number)
b. Standards that the products comply with (i.e. 16 CFR Part 1630)
c. Contact information of the importer or domestic manufacturer
d. Production information (Place of origin, manufacturing date)
e. Information about the testing agency (where the product is tested)
A GCC is required for textiles that are covered by the FFA (excluding children’s sleepwear, for which a CPC is required). Here are some examples:
- Rugs and carpets
- Cushions and mattresses
Federal Hazardous Substances Act (FHSA)
The FHSA regulates household products that contain potentially dangerous substances such as corrosive, reactive, and toxic substances. The FHSA requires labeling to alert consumers about the potential hazards and what they need to do to protect themselves from hazards.
The FHSA also covers flammable chemicals and fire retardants that are commonly used in the textile industry. Formaldehyde, which is a chemical substance used to increase wrinkle and crease resistance in textiles, is an example of a substance restricted under the FHSA.
You can learn more about this topic in this document.
CPSIA: Children’s Clothing
The Consumer Product Safety Improvement Act (CPSIA) regulates products that are intended to be used by children below the age of 12 years old, including clothing and textile products used by children.
Examples of textile products that are intended to be used by children include:
- Children’s outfits
- Children’s sleepwear
- Children’s socks and stockings
Below are CPSC’s safety standards that might be relevant for children’s clothing:
a. 16 CFR Part 1615 – Standard for the Flammability of Children’s Sleepwear: Sizes 0 through 6x (ff 3-71)
b. 16 CFR Part 1616 – Standard for the Flammability of Children’s Sleepwear: Sizes 7 through 14 (ff 5-74)
c. 16 CFR Part 1308 – Prohibition of Children’s Toys and Child Care Articles Containing Specified Phthalates
To comply with the CPSIA requirements, importers or manufacturers of children’s clothing prepare the following documents:
a. Tracking Label containing manufacturer’s name, location, date of production, and other information
c. Valid test reports issued by CPSC-recognized lab, demonstrating that the products comply with applicable safety standards
Additional requirements might apply, according to the product.
Substantial Product Hazard List (16 CFR Part 1120) – Drawstrings in Children’s Upper Outerwear
The CPSC determined that there are certain consumer products have the characteristics whose existence presents a substantial product hazard to the users. It specified these products and sets out rules and standards for them under CFR 16 Part 1120 – Substantial Product Hazard List.
The CPSC has listed children’s upper outerwear with hood and neck drawstrings in sizes 2T to 12 in Part 1120 – Substantial Product Hazard List because such products present a strangulation hazard to the children.
Importers and manufacturers of such products should make sure that their products comply with the requirements of ASTM F 1816-97 Drawstrings on Children’s Upper Outerwear.
ASTM Textiles Standards
The American Society for Testing and Materials (ASTM) is an international organization that develops and issues standards for a wide range of materials, and products. In many cases, ASTM Standards are voluntary. An ASTM Standard is compulsory when it is incorporated into a Federal or state regulations, such as ASTM F1816 Drawstrings on Children’s Upper Outerwear (incorporated under CFR 16 Part 1120)
ASTM D1230 – Standard Test Method for Flammability of Apparel Textiles
ASTM D 1230 is a test method to evaluate the flammability of textile fabrics that are intended to be made into clothing.
The test method describes the response of materials, products, or assemblies to heat and flame under controlled conditions.
ASTM D5489 – Standard Guide for Care Symbols for Care Instructions on Textile Products
ASTM D5489 is a standard that established a uniform system of symbols for care instructions on textile products, including garments and fabric furniture used in household or public venues.
The standard provides a comprehensive system of symbols to represent care instructions for textile products. It also aims to provide a set of concise and easy-to-understand care symbols to reduce users’ dependency on the instruction language.
ASTM F1816 Standard Safety Specification for Drawstrings on Children’s Upper Outerwear
ASTM F1816 is a standard that concerns the safety of drawstrings on children’s upper outerwear. It covers children’s upper outwear in sizes 2T to 12 (for neck/hood drawstrings) or 2T to 16 (for waist/bottom drawstrings).
This standard aims to reduce the strangulation and vehicular dragging hazards related to such products. Examples of products covered by this standard include:
- Children’s jackets
- Children’s sweatshirts
- Children’s hoodies
ASTM F1816 does not cover children’s upper outerwear with fully retractable drawstrings.
Textile, Wool and Fur Acts and Rules
The Federal Trade Commission(FTC) sets labeling requirements for most clothing and home textile products
- Curtains and casements
- Rugs, carpets, and mats
- Yarns, and fabrics
- Secondhand household textile items
Textile and apparel products to be sold in the United States must be labeled with the following information:
- Fiber content
- Importer or manufacturer identity or Registered Identification Number (RN)
- Size (suggested)
Here we list some common textile fibers and its attribute:
- Silk – Smooth fabric finish with shine surface
- Wool – Warmth
- Cotton – Lightweight and absorbent
- Nylon – Durable, strong, lightweight, and dries quickly
- Polyester – Durable, strong, lightweight, and dries quickly
- Cashmere wool – Softness
In general, the label must be conspicuous and accessible on the inside or outside the product.
Label Placement Examples
a. For garments, the label could be attached near the inside center of the neck. The fiber content and manufacturer could be disclosed on another label attached to a side beam
b. For skirts, the label could be placed inside of the waistband
c. For pillowcases, the label could be attached on the inside close to the open end.
Care Labeling of Textile Wearing Apparel & Certain Piece Goods
Care instructions are required under the FTC labeling rule. Importers and manufacturers must attach the care instructions permanently to their products.
Care symbols are standardized under ASTM D5489 – Standard Guide for Care Symbols for Care Instructions on Textile Products
Care labels must state what regular care is necessary for the ordinary use of the product. For example, if the garment cannot be cleaned without harm, a warning sign should be provided.
Guides for Select Leather and Imitation Leather Products
The FTC specifies the labeling requirements for products that are made of leather or imitation leather. It requires that manufacturers, importers, or sellers of leather or imitation leather products must provide an authentic product description on the label, regarding the following aspects:
You can learn more about this topic on this page..
California Proposition 65
California Proposition 65 restricts chemicals that are deemed to cause cancer or reproductive harm. Businesses with 10 or more employees must provide warning labels on their products if the product contains any restricted chemical, in an amount above the set limit.
The proposition applies to consumer products including children’s and adult products sold in California, including apparel and textiles.
Here we list some restricted substances that might be contained in textiles products:
- Lead acetate
How do I know which chemicals and heavy metals are restricted?
You can check this list to learn more about restricted substances. However, lab testing is often the only way to confirm if your product contains restricted substances above the limit set by California Proposition 65.
Here are some examples of labs that offer lab testing against California Proposition 65:
- TÜV Rhineland
Country of Origin Marking
The country of origin labeling is mandatory for many products, and it shall be permanently affixed on the product and the label. Also, the country of origin label should not be covered by any other label.
- Made in China
- Made in Vietnam
- Made in Thailand
Country of Origin Rules
The country of origin label must represent the actual manufacturing country. You are not allowed to claim that the product is manufactured elsewhere by, for example, shipping the product for relabeling or repacking in a third country.
Made in USA
Manufacturers promoting their products as “Made in USA”, must meet the following requirements:
a. Assembly and processing of the product must be done in the US
b. If the product is not entirely processed in the US, the claim should include the description of the amount of domestic content or processing
c. All components and materials must be sourced in the US
The English language is mandatory. However, other languages can be added in addition to the English language version of the label.
Clothing Lab Testing
To confirm whether your clothing complies with the applicable safety standards and regulations, you should arrange a lab test for your products, regarding substance restrictions, flammability, and other requirements.
Here is a list of international lab testing companies that offer textile testing services:
- TÜV SÜD
What is the Wool Products Labeling Act?
Besides complying with the general textiles regulations described in this article, a wool product must also comply with the Wool Products Labeling Act.
Generally speaking, the requirements of the Wool Products Labeling Act are similar to the general textiles labeling regulations. However, this Act explains exactly how you shall calculate the percentage of wool present in the product – as it’s compulsory to specify this information in the labeling.
Note that the following items are not covered by the act:
- Carpets, rugs or mats, which are covered by the Textile Act and Rules
- Wool products made for export
What is the Fur Products Labeling Act?
The Fur Products Labeling Act (FPLA) is an FTC regulation that imposes specific labeling requirements to any company manufacturing, importing or selling fur garments and accessories in the U.S.
The labeling shall includes the following information:
- The animal name in accordance with the Fur Products Name Guide;
- The name or Registered Identification Number (RN) of the manufacturer, importer or seller;
- The country of origin for imported fur products;
- If the fur is used or damaged.
Note that it is not enough for a product to comply with the FPLA, as it must also comply with the general textile labeling requirements.
Do the same regulations apply to children’s clothing as to clothing for adults?
The same textiles labeling requirements apply. However, children’s products, including clothing and other textiles products, must also comply with CPSIA.