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US Clothing Flammability Standards: What Importers Need to Know

Last updated: October 20, 2026

Almost all clothing sold in the United States must meet the CPSC's Standard for the Flammability of Clothing Textiles, 16 CFR Part 1610, also called the general wearing apparel standard. The standard classifies fabrics by how fast they burn and keeps dangerously flammable fabrics out of clothing. Many ordinary fabrics are exempt from testing, but exempt from testing is not the same as exempt from the standard.

What the standard covers

16 CFR 1610 applies to clothing and to textiles intended for use in clothing, including adult apparel and children's daytime clothing. Children's sleepwear sizes above 9 months up to 14 are covered by the stricter standards described in US Children's Sleepwear Regulations. Garments that qualify as exceptions to the sleepwear standards, such as tight-fitting sleepwear and infant garments, must still meet 1610.

The three flammability classes

The standard classifies textiles by burning speed and characteristics:

Class Meaning
Class 1 Normal flammability. Acceptable for clothing
Class 2 Intermediate flammability. Acceptable only in limited cases defined by the standard
Class 3 Rapid and intense burning. Dangerously flammable and not allowed in clothing

Testing exemptions

Years of testing show that many fabrics consistently pass, so the standard lists fabrics that are exempt from testing, including certain plain-surface fabrics and certain fabrics made of specific fibers. The CPSC stresses that these are testing exemptions, not exemptions from the requirement itself. Some items, such as certain hats, gloves and footwear, are also outside the standard's scope. Check the exact list in 16 CFR 1610.1(d) before relying on an exemption.

Fabrics with a raised surface, such as brushed, napped or fleece-type fabrics, are the usual testing risk, because their surface can burn faster. Test them before production.

Importer responsibilities

Manufacturers, importers and retailers are expected to evaluate the flammability of apparel before sale. In practice, that means:

  1. Classify the product. Is it adult, children's or sleepwear?
  2. Decide whether the fabric is exempt from testing or must be tested, and record why.
  3. Test when required, using reasonable and representative testing.
  4. Issue the right certificate. Children's products need a Children's Product Certificate based on third-party testing. For adult apparel, a General Certificate of Conformity may be required, although the CPSC has said it will not enforce the certificate requirement for adult apparel that relies on the testing exemption.
  5. Keep records for at least five years.

eFiling since July 8, 2026

Importers must now submit certificate data electronically at the time of entry for regulated products that require a CPC or GCC. Adult apparel relying on the 1610.1(d) exemption is among the cases the CPSC's eFiling guidance treats separately, so confirm how it applies to each product with your customs broker. See Apparel Supplier Compliance Checklist for US Importers.

Flammability and your product data

Store the fabric type, surface (plain or raised), weight, exemption basis and test report reference for every style. This is also part of a textile compliance matrix.

Frequently asked questions

Is cotton exempt? It depends on the surface and weight. Many plain-surface cotton fabrics are exempt from testing, while raised-surface cotton may not be.

Do I need a lab test for every style? Not if the fabric is exempt from testing, but you must be able to show why.

Does the standard apply to imported garments? Yes. Imports must comply when they enter the U.S.

What happens to garments that fail? They cannot be sold, and the CPSC can require corrective action.

Related guides

This article is general information, not legal advice. Confirm requirements with the CPSC or an accredited lab.

Sources