Monday, January 12, 2009

16 CFR 1610 Flammability Requirement under CPSIA

According to CPSIA, Wearing Apparel Flammability - 16 CFR 1610 is required for both children's and adult's apparels. But certain products may be exempted from testing requirement subjected to following conditions:

Specific Exceptions -
  1. Hats, provided they do not constitute or form part of a covering for the neck, face, or shoulders when worn by individuals;
  2. Gloves, provided they are not more than 14 inches in length and are not affixed to or do not form an integral part of another garment;
  3. Footwear, provided it does not consist of hosiery in whole or part and is not affixed to or does not form an integral part of another garment;
  4. Interlining fabrics, when intended or sold for use as a layer between an outer shell and an inner lining in wearing apparel.

Specific Exemptions -

  1. Plain surface fabrics, regardless of fiber content, weighing 2.6 ounces per square yard or more; and:
  2. All fabrics, both plain surface and raised-fiber surface textiles, regardless of weight, made entirely from any of the following fibers or entirely from combination of the following fibers: acrylic, modacrylic, nylon, olefin, polyester, wool.

Summary of Test Criteria for Specimen Classification
Plain surface textile fabric
Class 1: Burn time is 3.5 seconds or more, then ACCEPTABLE
Class 2: This class is not applicable to plain surface textile fabrics
Class 3: Burn time is less than 3.5 seconds, then NOT ACCEPTABLE

Raised surface textile fabric
Class 1: (1) Burn time is greater than 7.0 seconds; or (2) Burn time is 0-7 seconds with no base burns (SFBB). Exhibits rapid surface flash only, then ACCEPTABLE.
Class 2:
Burn time is 4–7 seconds (inclusive) with base burn (SFBB), then ACCEPTABLE.
Class 3:
Burn time is less than 4.0 seconds with base burn (SFBB), then NOT ACCEPTABLE.

Even though the some fabrics may be exempted from the flammability test, the Certificate of Conformity is still required.


  1. Question:
    If all fabrics are exempt, is third party testing still required, or can the manufacturer (of the finished garment) issue a GCC?

  2. Theoretically, it is no required for testing for flammability if exempted under CPSIA. And manufacturer should issue GCC by themselves. But sometimes, manufacturer will ask 3rd party lab to vertify the exemption on the flammability for keep safe before issuing GCC.

  3. would baby mittens(for 0 to 6mos old babies) be an exception as they are only 4 1/2 inches in length? do baby mittens fall under the glove category?