NISTIR 8115

A Guide to United States

Apparel and 

Household Textiles 

Compliance 

Requirements
A Guide to United States

Apparel and Household Textiles 

Compliance Requirements

Lisa M. Benson

Karen Reczek

This publication is available free of charge from:

http://dx.doi.org/10.6028/NIST.IR.8115

NISTIR 8115 
NISTIR 8115 

A Guide to United States

Apparel and Household Textiles 

Compliance Requirements

Lisa M. Benson*

Karen Reczek

Standards Coordination Office

* Dakota Consulting

This publication is available free of charge from:

http://dx.doi.org/10.6028/NIST.IR.8115

March 2012 

Revised June 2016

U.S. Department of Commerce 

Penny Pritzker, Secretary 

National Institute of Standards and Technology 

Willie May, Under Secretary of Commerce for Standards and Technology and Director 
Acknowledgements

The lead author for this document is Lisa M. Benson, Dakota Consulting, under contract to the 

Standards Coordination Office of NIST. Additional guidance, initial research, and review of the 

document were provided by the staff of the Standards Coordination Office of NIST including: 

Mary Donaldson and Karen Reczek. Invaluable support was also received from the 

knowledgeable experts at the Consumer Product Safety Commission and the Federal Trade 

Commission who provided input into the document and also conducted a thorough 

review. Consumer Product Safety Commission reviewers were Patty Edwards and Arlene Flecha 

Castro. Federal Trade Commission reviewers were Steve Ecklund and Robert Frisby.

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Table of Contents

HOW TO USE THIS GUIDE............................................................................................................. 1

SCOPE ..................................................................................................................................... 1

OVERVIEW OF U.S. FEDERAL REGULATORY FRAMEWORK...................................................................... 1

FEDERAL REGULATORY AUTHORITIES AND TECHNICAL REGULATIONS (MANDATORY).................................... 2

Consumer Product Safety Commission (CPSC) ............................................................................ 2

Consumer Product Safety Act (CPSA)...................................................................................... 2

Consumer Product Safety Improvement Act of 2008 (CPSIA)............................................... 2

Children’s Apparel and Sleepwear Only .................................................................................. 2

Certificates and Mandatory Third-Party Testing..................................................................... 3

Tracking Labels for Children’s Apparel .................................................................................... 4

Soft Infant and Toddler Carriers.............................................................................................. 4

Drawstrings in Children’s Upper Outerwear........................................................................... 5

Flammable Fabrics Act............................................................................................................. 5

Flammability of Clothing.......................................................................................................... 5

Flammability of Vinyl Plastic Film............................................................................................ 6

Flammability of Children’s Sleepwear..................................................................................... 6

Flammability of Carpets and Rugs........................................................................................... 7

Flammability of Mattress Sets, Mattresses, and Mattress Pads............................................. 7

Federal Hazardous Substances Act (FHSA).............................................................................. 9

Sharp Points and Edges on Children’s Products.................................................................... 10

Ban on Infant Cushions.......................................................................................................... 10

Standard on Window Coverings and Cords........................................................................... 10

Pending Regulations of Note................................................................................................. 11

Customs and Border Protection (CBP)....................................................................................... 11

Country of Origin: Marking of Imported Articles and Containers......................................... 11

Environmental Protection Agency (EPA) ................................................................................... 11

Antimicrobial Clothing and Household Textiles: The Federal Insecticide, Fungicide, and 

Rodenticide Act (FIFRA)......................................................................................................... 11

Toxic Substance Control Act (TSCA) ...................................................................................... 12

Federal Trade Commission (FTC)............................................................................................... 13

Federal Trade Commission Act (FTC Act) .............................................................................. 13

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The Textile Fiber Products Identification Act ........................................................................ 13

Used or Secondhand Stuffing ................................................................................................ 14

Bamboo Claims...................................................................................................................... 15

The Wool Products Labeling Act of 1939 .............................................................................. 15

Fur Products Labeling Act (FPLA)........................................................................................... 16

Truth in Fur Labeling Act of 2010 .......................................................................................... 16

Cat and Dog Fur Products...................................................................................................... 17

Leather Products.................................................................................................................... 17

Environmental Claims............................................................................................................ 17

Care Labels............................................................................................................................. 18

Pending Regulations of Note................................................................................................ 18

United States Department of Agriculture (USDA)..................................................................... 19

Organic Fibers: Organic Foods Production Act of 1990 (OFPA) ............................................ 19

OVERVIEW OF U.S. STATE REGULATORY FRAMEWORKS...................................................................... 19

STATE REGULATORY AUTHORITIES AND TECHNICAL REGULATIONS (MANDATORY)..................................... 19

Packaging and Labeling ............................................................................................................ 20

UPLR....................................................................................................................................... 20

Toxics in Packaging Legislation.............................................................................................. 20

Uniform Law Label................................................................................................................. 21

State of California...................................................................................................................... 21

Lead and Other Toxic Substances.......................................................................................... 21

Safer Consumer Products Regulations.................................................................................. 22

Plumage Regulations............................................................................................................. 22

Flammability of Upholstered Furniture and Bedding............................................................ 22

Made in the USA.................................................................................................................... 23

Connecticut................................................................................................................................ 23

Safe Children’s Products........................................................................................................ 23

State of Illinois........................................................................................................................... 24

Lead........................................................................................................................................ 24

Minnesota ................................................................................................................................. 25

Formaldehyde in Children’s Products ................................................................................... 25

Washington State...................................................................................................................... 25

Lead, Cadmium, and Phthalates in Children’s Products........................................................ 25

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Multiple States .......................................................................................................................... 25

Flame Retardant Regulations................................................................................................ 25

Fur Labeling ........................................................................................................................... 25

Dog and Cat Fur..................................................................................................................... 26

Chemicals of Concern ............................................................................................................ 26

Crib Bumpers......................................................................................................................... 26

OVERVIEW OF THE U.S. VOLUNTARY STANDARDS FRAMEWORK ........................................................... 27

STANDARDS DEVELOPING ORGANIZATIONS (SDOS) .......................................................................... 27

American Association of Textile Chemists and Colorists (AATCC)............................................. 27

ASTM International ................................................................................................................... 28

TESTING AND CERTIFICATION BODIES ............................................................................................. 30

Testing....................................................................................................................................... 30

Certification............................................................................................................................... 30

RELEVANT U.S. GOVERNMENT AGENCIES ....................................................................................... 30

U.S Customs and Border Protection (CBP) ................................................................................ 30

U.S. Consumer Product Safety Commission (CPSC)................................................................... 31

Environmental Protection Agency (EPA) ................................................................................... 31

Federal Trade Commission ........................................................................................................ 31

U.S. Department of Agriculture................................................................................................. 31

U.S. APPAREL AND HOUSEHOLD TEXTILES INDUSTRY AND MARKET DATA ............................................... 32

Industry Trade Associations ...................................................................................................... 32

Apparel and Household Textiles Market Data .......................................................................... 32

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A Guide to United States

Apparel and Household Textiles

Compliance Requirements

 

SCOPE

This guide addresses apparel, including children’s apparel, and household textiles. It does not 

include other textiles, such as sleeping bags, tents, sporting goods, or other non-household 

products that contain or are made from textile materials. 

OVERVIEW OF U.S. FEDERAL REGULATORY FRAMEWORK

Once a law has been enacted by Congress, the appropriate federal agency (e.g., the Consumer 

Product Safety Commission, the Federal Trade Commission, the National Highway Traffic and 

Safety Administration, et al.) may create the regulations to implement the law. Before such 

regulations can be adopted, the appropriate federal agency ordinarily will issue a notice of 

proposed rulemaking (NPRM) to solicit public comments on the proposed rules. To provide 

opportunity for public comment, the appropriate federal agency must issue draft regulations or 

“Proposed Rules” that are published in the Federal Register and as a WTO TBT notification. The 

agency reviews the comments and can then issue a “Final Rule” that also is published in the 

Federal Register, and later, published annually in the Code of Federal Regulations (CFR).

Together, the enabling acts and laws [published in the United States Code (USC) once passed] 

and the final regulations (published in the CFR) provide a framework for the implementation 

and enforcement of most federal laws in the United States.

HOW TO USE THIS GUIDE

 Regulations are mandatory

 Standards are voluntary (unless “Incorporated by Reference” in a regulation)

 Guidelines may be voluntary (but are often de facto industry standards)

 “Red” text highlights mandatory requirements 

 “Blue” text indicates a hyperlink to a website, page or document on the web

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FEDERAL REGULATORY AUTHORITIES AND TECHNICAL REGULATIONS (MANDATORY)

Several U.S. federal agencies administer regulations associated with apparel and textiles. 

Agency Scope

Consumer Product Safety Commission (CPSC) Flammability; children’s products; hazardous 

substances

Customs and Border Protection (CBP) Country of origin for most imported products

Environmental Protection Agency (EPA) Pesticides; Toxic Substances 

Federal Trade Commission (FTC) Labeling (care labeling, fiber content labeling, 

environmental labeling, country of origin 

labeling, advertising)

United States Department of Agriculture 

(USDA)

Organic claims

Consumer Product Safety Commission (CPSC)

Consumer Product Safety Act (CPSA)

Title 15, United States Code, Chapter 47, Sections 2051-2089

The Consumer Product Safety Act, entered into law on October 27, 1972, was enacted to 

establish the Consumer Product Safety Commission and define its authority with the purpose of 

protecting the public against unreasonable risks of injury associated with consumer products; 

assisting consumers in evaluating the comparative safety of consumer products, developing 

uniform safety standards for consumer products; and promoting research and investigation into 

the causes and prevention of product-related deaths, illnesses, and injuries.

Consumer Product Safety Improvement Act of 2008 (CPSIA)

Public Law 110–314, August 14, 2008

On August 14, 2008, President Obama signed into law Public Law 110-314 (Consumer Product 

Safety Improvement Act of 2008). On August 12, 2011, he signed into law amendments to the 

Act, Public Law 112–28, August 12, 2011. The Act provided CPSC with significant new 

regulatory and enforcement tools as part of amending and enhancing several CPSC statutes, 

including the Consumer Product Safety Act.

Children’s Apparel and Sleepwear Only

The Consumer Product Safety Improvement Act (CPSIA) enacted in 2008 regulates specific 

substances in children’s products, including children’s apparel and sleepwear. The CPSIA sets

limits for lead content and phthalates in children’s products. A children’s product is defined as a 

consumer product designed or intended primarily for children age 12 years or younger. 

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With respect to children’s apparel, Section 101(a) of the CPSIA restricts children’s products, 

including children’s apparel and sleepwear, to a lead content limit of 100 parts per million 

(ppm). In addition, the use of paint or similar surface coating on children’s apparel and 

sleepwear must not exceed a lead content limit of 90 ppm. The CPSC recently revised 16 CFR

1500.91(d)(7) to clarify that the Commission has determined that textiles that have treatments 

and applications consisting entirely of dyes do not exceed the lead content limits and are not 

subject to the third party testing requirements for children's products, so long as those 

materials have not been treated or adulterated with materials that could add lead.

Additionally, section 108 of CPSIA states that children’s toys and child care articles cannot 

contain more that 0.1% of six phthalates - DEHP, DBP, BBP limits are applicable to both toys 

and child care items while DINP, DIDP, and DnOP limits are applicable only to toys that can be 

placed in the mouth and are intended for children 3 and younger. Although children’s 

clothing does not need to be certified to this requirement, children’s sleepwear or bibs (child 

care article) intended for children age 3 years or younger and any children’s textile product 

that is intended for use in play (toy) must be certified to the phthalates requirements.

Certificates and Mandatory Third-Party Testing

Section 102 of the CPSIA requires every manufacturer or importer of all consumer products 

that are subject to a consumer product safety rule enforced by the CPSC to issue a general 

certificate of conformity based on testing of the product and stating that the product complies 

with the applicable standard, regulation, or ban. The certificate must accompany the product 

and be furnished to the retailer or distributor. Section 102 also requires the manufacturers or 

importers of children’s products (products designed and intended primarily for children age 

12 years or younger) to certify that the products comply with all relevant product safety 

standards by issuing a children’s product certificate supported by tests performed by a CPSCaccepted third-party testing laboratory that has been accredited. CPSC also has regulations 

pertaining to certificates of compliance; they can be found at 16 CFR 1110.

Every manufacturer of a non-children’s product (and the private labeler of such product, if such 

product bears a private label) is subject to CPSC regulations pertaining to: 

 Carpets and rugs (16 CFR 1630 and 1631) 

 Vinyl plastic film (16 CFR 1611) 

 Wearing apparel (16 CFR 1610) 

For more detailed information, see CPSC’s:

Testing and Certification and

FAQs - Certification and Third-Party Testing 

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Tracking Labels for Children’s Apparel

Tracking labels are required for all products that are designed and intended primarily for 

children ages 12 and younger, including children’s apparel. The tracking label must be affixed 

to the product (to the extent practical) and packaging, visible, legible, and provide certain basic 

identifying information, including:

 Manufacturer or private labeler name;

 Location and date of production of the product;

 Detailed information on the manufacturing process, such as a batch or run number, or 

other identifying characteristics; and

 Any other information to facilitate ascertaining the specific source of the product.

For more detailed information, see CPSC’s:

Tracking Label Requirements for Children’s Products

Soft Infant and Toddler Carriers

Section 104 of the CSPIA required CPSC to promulgate consumer safety standards for durable 

infant and children’s products. In response to this, the CPSC has issued a final rule, 16 CFR 1226

Safety Standard for Soft Infant and Toddler Carriers.

Each soft infant and toddler carrier must comply with all applicable provisions of ASTM 

F2236-14, which has been incorporated by reference. The standard includes general 

requirements that the products must meet, as well as specified test methods to ensure 

compliance with the general requirements, which include:

 restrictions on sharp points or edges, as defined by 16 CFR 1500.48 and .49;

 restrictions on small parts, as defined by 16 CFR 1501;

 restrictions on lead in paint, as set forth in 16 CFR 1303;

 requirements for locking and latching devices;

 requirements for permanent warning labels;

 restrictions on flammability, as set forth in 16 CFR 1610;

 requirements for toy accessories, as set forth in ASTM F 963;

 requirements on performance;

 requirements for warning labels.

In addition, under section 14 of CPSA (as amended by Sec 102(a)(1)(A) of the CPSIA) soft infant 

and toddler carriers are also subject to third party testing and certification requirements.

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Drawstrings in Children’s Upper Outerwear

In February 1996, CPSC issued guidelines which were incorporated into an industry voluntary 

standard to prevent children from strangling or becoming entangled on drawstrings from upper 

outerwear garments. In July 2011, CPSC approved a federal safety rule for drawstrings in 

children’s upper outerwear. Children’s upper outerwear in sizes 2T-16 must be in conformance 

with ASTM F1816-97, Standard Safety Specification for Drawstrings on Children's Upper 

Outerwear, approved June 10, 1997, published August 1998 (incorporated by reference in 16 

CFR 1120.3 (b), or such outerwear will be considered a substantial product hazard.

Flammable Fabrics Act

Title 15, United States Code, Chapter 25, Sections 1191-1204

The Flammable Fabric Act prohibits the manufacture for sale, the sale, or the offering for sale, 

in commerce, or the importation into the United States, or the introduction, delivery for 

introduction, transportation or causing to be transported, in commerce, or the sale or delivery 

after a sale or shipment in commerce of any product, fabric, or related material which fails to 

conform to flammability standards or regulations issued under this Act. Standards have been 

established for the flammability of clothing textiles, vinyl plastic film (used in clothing), carpets 

and rugs, children's sleepwear, and mattresses and mattress pads.

This Act is applicable to all fabric, which is defined in the Act as “any material (except fiber, 

filament, or yarn for other than retail sale) woven, knitted, felted, or otherwise produced from 

or in combination with any natural or synthetic fiber, film, or substitute thereof which is 

intended for use or which may reasonably be expected to be used, in any article of wearing 

apparel or interior furnishing.”

For more detailed information, see CPSC’s:

Flammable Fabrics Act

Flammability of Clothing

16 CFR 1610 – Standard for the Flammability of Clothing Textiles provides methods of testing 

the flammability of clothing and textiles intended to be used for clothing by classifying fabrics 

into three classes of flammability based on their speed of burning. This minimum standard 

specifies that textiles used in apparel must meet class 1 or 2 flammability requirements. Class 

3 textiles, the most dangerously flammable fabrics, are unsuitable for use in clothing because of 

their rapid and intense burning characteristics.

For more detailed information, see CPSC’s:

Regulatory Summary for Flammable Fabrics Act and

Laboratory Test Manual for 16 CFR Part 1610: Standard for the Flammability of Clothing 

Textiles 

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Flammability of Vinyl Plastic Film

Vinyl plastic film used in apparel must comply with 16 CFR 1611 - Standard for the 

Flammability of Vinyl Plastic Film. The standard applies to all uncovered or exposed parts of

wearing apparel made from non-rigid, unsupported plastic, rubber or other synthetic or natural 

film or sheeting, including transparent, translucent, and opaque material, whether plain, 

embossed, molded, or otherwise surface treated, which is in a form or condition ready for use 

in wearing apparel, and includes film or sheeting exceeding 10 mils (0.254 mm) in thickness.

Flammability of Children’s Sleepwear

16 CFR 1615 Standard for the Flammability of Children's Sleepwear: Sizes 0 through 6X and 

16 CFR 1616 Standard for the Flammability of Children's Sleepwear: Sizes 7 through 14 establish 

mandatory flammability requirements for children’s sleepwear. Children’s sleepwear must be 

flame resistant and self-extinguish when exposed to a small ignition source. The rules cover 

all children’s sleepwear between size 9 months and size 14. The fabric, seams, trim, and 

garments must pass certain flammability tests or the garment must be tight-fitting as defined 

by specified dimensions.

All tight-fitting garments must meet the labeling requirements in the Standards, 16 CFR 

1615.1(o)(10) and (11) and 16 CFR 1616.2(o)(10) and (11). The Standards require a hangtag 

that must meet the specified tag size, font, text, and background color and a garment neck 

label that must meet the specified text, layout, placement, and line border for tight-fitting 

children’s sleepwear. Tight-fitting sleepwear must bear the specified garment label (Figure 1) 

and yellow hangtag (Figure 2) unless the garment is sold in a package, in which case, the 

package must have the yellow label.

Tight fitting sleepwear must comply with all of the flammability requirements for clothing 

textiles (16 CFR 1610) or vinyl plastic film (if applicable).

Figure 1 - Tight-fitting sleepwear 

must also bear a label 

immediately below the size 

designation on the front of the 

sizing label located on the center 

back of the garment

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Figure2: Tight-fitting sleepwear 

must bear a specific hangtag 

bearing no other information or 

have a label on the packaging 

For more detailed information, see CPSC’s:

Sleepwear Policy and Loungewear Position Letter

and

Flammability of Children’s Sleepwear Test Manual

Flammability of Carpets and Rugs

Carpets and rugs must meet the flammability requirements as applicable in 16 CFR 1630 

Standard for the Surface Flammability of Carpets and Rugs or 16 CFR 1631 Standard for the 

Surface Flammability of Small Carpets and Rugs. These standards provide test methods to 

determine the surface flammability of carpets and rugs when exposed to a standard small 

source of ignition under carefully prescribed draft-protected conditions. They are applicable to 

all types of carpets and rugs used as floor covering materials regardless of their method of 

fabrication or whether they are made of natural or synthetic fibers or films, or combinations of 

or substitutes for these.

If the carpet or rug has had a fire-retardant treatment or is made of fibers that have had a fire 

retardant treatment, it must be labeled with the letter “T”. The letter “T” should be legible and 

conspicuous on the label and/or invoice or other paper related to the carpet and rug if 

commercially installed. Small carpets and rugs not meeting the acceptance criterion of the 

standard must be permanently labeled with the following statement:

FLAMMABLE (FAILS U.S. DEPARTMENT OF COMMERCE STANDARD FF 2-70): 

SHOULD NOT BE USED NEAR SOURCES OF IGNITION

Flammability of Mattress Sets, Mattresses, and Mattress Pads 

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

16 CFR 1633, Standard for the Flammability (Open Flame) of Mattress Sets set forth the 

flammability requirements for mattresses and mattress pads and mattress sets, respectively. 

16 CFR 1632 requires prototype designs of mattresses and mattress pads, before the sale in 

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commerce or the introduction in commerce, to comply with the flammability requirements of 

this standard. The standard prescribes a test to determine the ignition resistance of a mattress 

or a mattress pad when exposed to a lighted cigarette.

Additionally, each mattress or mattress pad must be permanently labeled with the city and 

state location and the month and year of manufacture. Mattress pads treated with a 

chemical flame retardant must be labeled prominently with the letter “T” and with 

instructions on how to protect the pads from chemicals that will reduce the flame resistant 

properties.

16 CFR 1633 establishes flammability requirements that all prototype designs of mattress sets 

must meet before sale or introduction into commerce. The test method set forth in this 

regulation measures the flammability performance (fire test response characteristics) of a 

mattress (or mattress set) prototype by exposing the specimen to a specified flaming ignition 

source and allowing it to burn freely under well-ventilated, controlled environmental 

conditions. All mattress sets must meet the flammability performance requirements of this 

regulation.

Each mattress or mattress set shall bear a permanent, conspicuous, and legible label(s) 

containing the following information (and no other information) in English: 

 Name of the manufacturer, or for imported mattress sets, the name of the foreign 

manufacturer and importer.

o For mattress sets produced in the United States, the complete physical address 

of the manufacturer.

o For imported mattress sets, the complete address of the foreign manufacturer, 

including country, and the complete physical address of the importer or the 

United States location where the required records are maintained if different 

from the importer.

 Month and year of manufacture.

 Model identification.

 Prototype identification number for the mattress set. A statement identifying whether 

the manufacturer intends the mattress to be sold alone or with a foundation.

o For mattresses intended to be sold without a foundation, the label shall state 

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

o For mattresses intended to be sold with a foundation, the label shall state “THIS 

MATTRESS IS INTENDED TO BE USED WITH FOUNDATION(S): < Foundation ID >.”

o For mattresses intended to be sold both alone and with a foundation, the label 

shall state “THIS MATTRESS IS INTENDED TO BE USED WITHOUT A FOUNDATION 

OR WITH FOUNDATION(S): < Foundation ID >.”

 A certification on the label that the mattress complies with this standard.

o For mattresses intended to be sold without a foundation, a certification stating 

“This mattress meets the requirements of 16 CFR Part 1633 (federal flammability 

(open flame) standard for mattresses) when used without a foundation.”

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o For mattresses intended to be sold with a foundation, a certification stating “This 

mattress meets the requirements of 16 CFR Part 1633 (federal flammability 

(open flame) standard for mattresses) when used with foundation < ID >.” Such 

foundation(s) shall be clearly identified by a simple and distinct name and/or 

number on the mattress label.

o For mattresses intended to be sold both alone and with a foundation, a 

certification stating “This mattress meets the requirements of 16 CFR Part 1633 

(federal flammability (open flame) standard for mattresses) when used without a 

foundation or with foundation(s) < ID >.” Such foundation(s) shall be clearly 

identified by a simple and distinct name and/or number on the mattress label.

For more detailed information, see CPSC’s:

Test Manual

76 FR 59014 -- 16 CFR Part 1632 -- Standard for the Flammability of Mattresses and 

Mattress Pads; Technical Amendment -- 23 September 2011

(Note: 1632.4(a)(2) – ignition source – is revised) and

75 FR 72944 -- 16 CFR Parts 1632 and 1633 -- Third Party Testing for Certain 

Children’s Products; Mattresses, Mattress Pads, and/or Mattress Sets: Revisions to 

Terms of Acceptance of Children’s Product Certifications Based on Third Party 

Conformity Assessment Body Testing Prior to Commission’s Acceptance of 

Accreditation -- 29 November 2010

Federal Hazardous Substances Act (FHSA)

Title 15, United States Code, Chapter 30, Sections 1261-1278

16 CFR 1500, Federal Hazardous Substances Act (FHSA) Regulations

FHSA regulations set forth requirements for hazardous household substances in products. The 

FHSA requires household substances that meet the definition of hazardous (as defined in the 

Act) to bear cautionary labeling to warn the consumer of the hazard(s) associated with the 

use of the product, that would enable the consumer to safely use and store the product, first 

aid instructions where applicable, and the statement “Keep out of the reach of 

children.” Whether a product must be labeled depends on its formulation and the likelihood 

that consumers will be exposed to any hazards it presents in reasonable and foreseeable

customary use, which includes ingestion by children. The FHSA also defines as banned 

hazardous substances those products that are intended for use by children that present an 

electrical, mechanical, or thermal hazard, with some exceptions. The Act also allows the 

Consumer Product Safety Commission to ban through rulemaking certain products that are so 

dangerous or the nature of the hazard is such that the cautionary labeling requirements are not 

adequate to protect consumers. 

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Sharp Points and Edges on Children’s Products

16 CFR 1500.48 “Technical requirements for determining a sharp point in toys and other articles 

intended for use by children under 8 years of age” sets forth the test method for determining if a 

sharp point, exposed in normal use or through reasonably foreseeable damage or abuse, on toys 

and other articles intended for use by children under 8 years of age presents a potential risk of 

injury by puncture or laceration under section 2(s) of the Federal Hazardous Substances Act. 

Likewise 16 CFR 1500.49 “Technical requirements for determining a sharp metal or glass edge 

in toys and other articles intended for use by children under 8 years of age” provides the sharp 

edge test method used to make a determination if metal or glass edges, exposed in normal use 

or as a result of reasonably foreseeable damage or abuse, on toys and other articles intended 

for use by children under 8 years of age present a potential risk of injury by laceration or 

avulsion under section 2(s) of the Federal Hazardous Substances Act. Children’s clothing and 

textile articles technically do not fall under the scope; however, children’s textiles and clothing 

that contain sharp points and edges may be considered a hazardous product and CPSC will 

request a voluntary product recall by the manufacturer or issue a mandatory recall. 

For more detailed information, see CPSC’s: 

Regulatory Summary for Requirements under the Federal Hazardous Substances Act: 

Labeling and Banning Requirements for Chemicals and Other Hazardous Substances

Ban on Infant Cushions

16 CFR Part 1500.18 (a) (16) – current info link bans infant cushions and pillows that have all of 

the following characteristics:

 A flexible fabric covering,

 Is loosely filled with a granular material such as plastic foam beads or pellets,

 Is easily flattened,

 Is capable of conforming to the body or face of an infant, and

 Is intended or promoted for the use by children under one year of age.

Standard on Window Coverings and Cords

The CPSC staff is working with the Window Covering Manufacturers Association (WCMA) to 

develop performance requirements and test methods to address strangulation hazards 

associated with window covering products that use cords and to standardize warnings 

regarding the hazards associated with inner cord loops, emphasizing the need for proper 

adjustment of inner cord stop devices. The voluntary standard "American National Standard for 

safety of corded window covering products" (ANSI/WCMA A.100.1) provides requirements for 

window covering products that address strangulation hazards associated with continuous cord 

loops, inner cords, and cord joiners. Although this standard is voluntary, the CPSC can and has 

requested a recall of window covering that pose a strangulation hazard.
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For more detailed information, see CPSC’s:

Window Blind Cords

Pending Regulations of Note

The CPSC has recently published in the Federal Register the following Notices of Proposed 

Rulemaking (NPRM). Each notice provides specifics as to the amendments under consideration

and makes a request for comments. See:

Notice of Proposed Rulemaking: Prohibition of Children's Toys and Child Care Articles 

Containing Specified Phthalates (December 30, 2014)

Notice of Proposed Rulemaking: Safety Standard for Sling Carriers (July 23, 2014)

Notice of Proposed Rulemaking: Certificates of Compliance (May 13, 2013)

Advance Notice of Propose Rulemaking: Corded Window Coverings; Request for Comments and 

Information (1/16/2015)

Customs and Border Protection (CBP)

Country of Origin: Marking of Imported Articles and Containers

Title 19, United States Code, Chapter 4, Section 1304

All products imported into the U.S. must conform to 19 CFR 134, Country of Origin Marking

regulations. These regulations require that every article of foreign origin (or its 

container) imported into the U.S. be marked in a conspicuous place as legibly, indelibly, 

and permanently as the nature of the article (or container) will permit, and in such a 

manner as to indicate to the ultimate purchaser in the U.S., the English name of the 

country of origin of the article at the time of importation.

For more detailed information, see CBP’s:

Terminology and Methods for Marking of Country of Origin on U.S. Imports

Environmental Protection Agency (EPA)

Antimicrobial Clothing and Household Textiles: The Federal Insecticide, Fungicide, and 

Rodenticide Act (FIFRA) 

Title 7, United States Code, Chapter 6, Section 136

This Act provides for federal regulation of the distribution, sale, and use of pesticides to protect 

human health and the environment. Products that kill or repel bacteria or germs are considered 

pesticides, and must be registered with the EPA prior to distribution or sale. The EPA will not 

register a pesticide until it has been tested to show that it will not pose an unreasonable risk 

when used according to the directions. This includes pesticides used on clothing or textiles to 

provide antimicrobial or other pesticidal characteristics. 
Page | 12

FIFRA does not allow companies to make public health pesticidal claims for any product 

distributed or sold unless the product has been approved and registered by EPA or is covered 

by an exemption from registration. The EPA will take action against companies that make such 

claims. 

For more detailed information, see EPA’s

Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA),

Consumer Products Treated with Pesticides, 

Pesticide Registration Notices by Year,

Pesticide Registration, and

Pesticide Product Labels

Toxic Substance Control Act (TSCA)

The Toxic Substances Control Act of 1976 (15 USC 2601-2692) provides EPA with authority to 

require reporting, record-keeping, and testing requirements, and restrictions relating to 

chemical substances and/or mixtures. Certain substances are generally excluded from TSCA, 

including, among others, food, drugs, cosmetics, and pesticides.

EPA has promulgated a significant new use rule (SNUR) for the use of hexabromocyclododecane 

and 1,2,5,6,9,10-hexabromocyclododecane (HBCD) as flame retardants in consumer textiles 

(other than for use in motor vehicles). The rule, effective November 23, 2015, will add a section 

to 40 CFR 721 to require persons who intend to manufacture (including import) or process 

these chemicals for the above stated use to notify EPA at least 90 days before commencing that 

activity. The required notification will provide EPA with the opportunity to evaluate the 

intended use and, if appropriate, to prohibit or limit that activity before it occurs. EPA is also 

finalizing a SNUR for long-chain perfluoroalkyl carboxylate (LCPFAC) chemical substances that 

are used as part of carpets or for treating carpets.

In addition, EPA is proposing to designate polybrominated diphenyl ethers (PBDEs), which are 

used as flame retardants, and benzidine dyes, which are used to dye textiles, as SNURs.

For more detailed information, see EPAs

Hexabromocyclododecane (HBCD),

Long-Chain Perfluorinated Chemicals (PFCs)

PBDE Action Plan, and

Benzidine Dyes Action Plan
Page | 13

Federal Trade Commission (FTC)

Federal Trade Commission Act (FTC Act)

Title 15, United States Code, Chapter 2, Subchapter I, Sections 41-58

The FTC Act broadly prohibits unfair or deceptive acts or practices in or affecting commerce. 

The commission will find deception if, either by the inclusion or exclusion of information, it is 

likely to: 

• Mislead consumers acting reasonably under the circumstances, and

• Affect the consumer’s choice or conduct, thereby leading to injury.

The FTC Act allowed the FTC to enact regulations intended to prohibit unfair or deceptive acts 

or practices. 

For more detailed information, see FTC’s:

Clothing and Textiles Resource from the FTC's Bureau of Consumer Protection (BCP) 

Business Center

The Textile Fiber Products Identification Act

Title 15, United States Code, Chapter 2, Subchapter V, Section 70

16 CFR 303, Rules and Regulations under the Textile Fiber Products Identification Act 

The importation, manufacture, sale , offer for sale, transportation for sale, distribution, or 

advertising of any textile fiber product which is misbranded or falsely or deceptively advertised 

is unlawful and is considered an unfair method of competition and an unfair and deceptive act 

or practice in commerce under the FTC Act. To avoid being considered misbranded, the Act 

requires that most textile products have a label attached listing: 

 the generic names and percentages by weight of the constituent fibers in the product; 

 the name under which the manufacturer or other responsible company does business 

or, in lieu thereof, the registered identification number (“RN number”) of such 

company; and 

 the name of the country where the product was processed or manufactured. 

The Textile Fiber Products Identification Act also contains advertising and record-keeping 

provisions.

A label is required to be affixed to each textile product and, where required, to its package or 

container in a secure manner. Such label shall be conspicuous and shall be of such durability as 

to remain attached to the product and its package throughout any distribution, sale, re-sale, 

and until sold and delivered to the ultimate consumer.

Each textile fiber product with a neck must have a label disclosing the country of origin affixed 

to the inside center of the neck midway between the shoulder seams or in close proximity to 

another label affixed to the inside center of the neck. The fiber content and RN or name of the 
Page | 14

company may be disclosed on the same label as the country of origin or on another 

conspicuous and readily accessible label or labels on the inside or outside of the garment. On all 

other textile products, the required information shall be disclosed on a conspicuous and readily 

accessible label or labels on the inside or outside of the product. The country of origin 

disclosure must always appear on the front side of the label. Other required information may 

appear either on the front side or the reverse side of a label, provided that the information is

conspicuous, readily accessible, and clearly legible.

Packaged hosiery products do not need a label on each piece of hosiery provided the required 

information is listed on the packaging label and is applicable to all hosiery inside the package. 

Socks must be marked on the front of their packages or on labels with the English name of the 

country of origin. This marking must be placed adjacent to the size designation. The marking 

must be done in a manner that is legible, indelible, conspicuous, readily accessible to the 

consumer, and as permanent as the nature of the article or package permits.

Packaged products, such as t-shirts, must have required labeling on the product and on the 

packaging, unless the product label is clearly visible through the packaging. 

A 2014 amendment to the Textile Rules allows hang-tags stating a fiber generic name, 

trademark, or fiber characteristics that do not disclose the product’s full fiber content; 

however, if the textile product contains any other fiber, the hang-tag must disclose clearly and 

conspicuously that it does not provide the product’s full fiber content (e.g., “This tag does not 

disclose the product’s full fiber content” or “See label for the product’s full fiber content”).

For more detailed information, see FTC’s:

Threading Your Way Through the Labeling Requirements Under the Textile and Wool 

Acts

Used or Secondhand Stuffing

16 CFR 303, Rules And Regulations Under The Textile Fiber Products Identification Act

Any upholstered product, mattress, or cushion which contains stuffing which has been 

previously used as stuffing in any other upholstered product, mattress, or cushion shall have 

securely attached thereto a substantial tag or label, at least 2 inches (5.08 cm) by 3 inches 

(7.62 cm) in size, and statements thereon conspicuously stamped or printed in the English 

language and in plain type not less than 1/3 inch (8.38 mm) high, indicating that the stuffing 

therein is composed in whole or in part of "reused stuffing," "secondhand stuffing," "previously 

used stuffing," or "used stuffing."

For more detailed information, see FTC’s: 

Threading Your Way Through the Labeling Requirements Under the Textile and Wool 

Acts
Page | 15

Bamboo Claims

If a textile product contains rayon, the FTC requires the marketer to label the product as 

containing rayon regardless of the source material used to make the rayon. The Textile Rules 

would not prohibit the non-deceptive use of the term bamboo to describe the source of the 

rayon fibers in the product, such as “Rayon made from Bamboo.” If the product contains 

bamboo fibers that have not been made into rayon or some other manufactured fiber, the FTC 

requires the marketer to label the product as containing bamboo. To advertise or label a 

product as bamboo instead of rayon requires competent and reliable evidence, such as 

scientific tests and analyses, to show that it is made of actual bamboo fiber that has not been 

made into a manufactured fiber such as rayon. The same standard applies to other claims, such 

as a claim that rayon fibers made from bamboo retain natural antimicrobial properties from the 

bamboo plant.

For more detailed information, see FTC’s:

How to Avoid Bamboozling Your Customers

The Wool Products Labeling Act of 1939

Title 15, United States Code, Chapter 2, Subchapter III, Section 68

16 CFR 300 Rules and Regulations under The Wool Products Labeling Act of 1939

The importation, manufacture, sale, offer for sale, transportation for sale, distribution, or 

advertising of any wool product which is misbranded or falsely or deceptively advertised is 

unlawful and is considered an unfair method of competition and an unfair and deceptive act 

or practice in commerce under the Federal Trade Commission Act. The Wool Products 

Labeling Act requires marketers to attach a label to each wool product disclosing:

 the percentages by weight of the wool, recycled wool, and other fibers accounting for 

5% or more of the product, and the aggregate of all other fibers;

 the maximum percentage of the total weight of the wool product of any non-fibrous 

matter; 

 the name under which the manufacturer or other responsible company does business 

or, in lieu thereof, the registered identification number (‘‘RN’’) of such company; and 

 the name of the country where the wool product was processed or manufactured.

A 2014 amendment to the Wool Rules allows certain hang-tags stating a fiber generic name,

trademark, or fiber characteristics that do not disclose the product's full fiber content; 

however, if the wool product contains any other fiber, the hang-tag must disclose clearly and 

conspicuously that it does not provide the product's full fiber content (e.g., “This tag does not 

disclose the product’s full fiber content” or “See label for the product’s full fiber content”)

The Wool Act also contains advertising and record-keeping provisions. 

Products containing fiber from other animals must comply with either the Fur Products 

Labeling Act or the Textile Products Identification Act.
Page | 16

For more detailed information, see FTC’s:

Threading Your Way Through the Labeling Requirements Under the Textile and Wool 

Acts

Cachet of Cashmere: Complying with the Wool Products Labeling Act

Fur Products Labeling Act (FPLA)

Title 15, United States Code, Chapter 2, Subchapter IV, Section 69 

16 CFR 301, Rules and Regulations Under the Fur Products Labeling Act (FPLA)

Any wearing apparel that is manufactured, imported, or sold that contains fur must comply 

with the labeling requirements under the Fur Products Labeling Act (FPLA). Fur products –

made either entirely or partly with fur — must have a label disclosing:

 whether the fur is natural or pointed, bleached, or dyed;

 the name of the animal;

 if the fur product is composed of more than 10 percent surface area of pieces;

 the country of origin of imported fur products, including the country of origin for 

imported furs made into fur products in the U.S.;

 any other information that is required or permitted; 

 the name or registered identification number (“RN”) of the manufacturer or dealer;

 if the fur is used or damaged.

The above required information also must appear on invoices and in advertising for the fur 

products.

Domestic fur products may be labeled to show origin, but the law does not require it. 

Domestic furs also may be labeled to show the particular state or part of the country in which 

they originated. 

Truth in Fur Labeling Act of 2010

Public Law 111–313

In December 2010, Congress passed the Truth in Fur Labeling Act. As of March 18, 2011, the 

FTC’s exemption to the Fur Products Labeling Act for fur products with a component value of 

$150 or less was no longer in effect.

For more detailed information, see FTC’s:

How to Comply with the Fur Products Labeling Act and

Clothing and Textiles
Page | 17

Cat and Dog Fur Products

Tariff Act OF 1930, Prohibition on Importation of Dog and Cat Fur Products

Title 19, United States Code, Chapter 4, Section 1308

19 USC 1308 prohibits the import, export, distribution, transportation, manufacture, or sale in 

the U.S. of products containing dog or cat fur. As of November 9, 2000, the Dog and Cat 

Protection Act of 2000 calls for the seizure and forfeiture of each item containing dog or cat fur. 

The Act amended the Fur Products Labeling Act to exclude dog and cat fur products from those 

items the FTC is authorized to exempt from the labeling and other requirements of the Fur Act 

and implementing regulations.

Leather Products

16 CFR 24, Guides for Select Leather and Imitation Leather Products

These guides apply to the manufacture, sale, distribution, marketing, or advertising of all kinds 

or types of leather or simulated leather, including footwear. 

Environmental Claims

16 CFR 260, Guides for the Use of Environmental Marketing Claims

These guides apply to environmental claims included in labeling, advertising, promotional 

materials, and all other forms of marketing, whether asserted directly or by implication, 

through words, symbols, emblems, logos, depictions, product brand names, or through any 

other means, including marketing through digital or electronic means, such as the Internet or 

electronic mail. The guides apply to any claim about the environmental attributes of a product, 

package, or service in connection with the sale, offering for sale, or marketing of such product, 

package, or service for personal, family or household use, or for commercial, institutional, or 

industrial use.

In 2012, an update by the FTC modified the existing guide sections on general environmental 

benefit, compostable, degradable, ozone, recyclable, and recycled content claims. It also added 

new sections on carbon offsets, certifications and seals of approval, free-of claims, non-toxic 

claims, made with renewable energy claims, and made with renewable materials claims.

For more detailed information, see FTC’s:

Environmental Claims: Summary of the Green Guides
Page | 18

Care Labels

16 CFR 423, Care Labeling of Textile Wearing Apparel and Certain Piece Goods as Amended

The Federal Trade Commission’s (FTC) Care Labeling Rule requires manufacturers and importers 

to attach care instructions to garments. The Rule requires that manufacturers or importers 

comply with the following:

 Provide instructions prescribing a regular care procedure for the garment, or provide 

warnings if the garment cannot be cleaned without harm.

 Have a reasonable basis for the care labeling instructions, including that following them, 

will cause no substantial harm to the product.

 Warn consumers about certain procedures that they may assume to be consistent with 

the instructions on the label, but that would harm the product. For example, if a pair of 

pants is labeled for washing, consumers may assume they can iron them. If the pants 

would be harmed by ironing, the label should read, "Do not iron."

 Ensure that care labels remain attached and legible throughout the useful life of the 

product.

Care labels must be attached to products prior to sale in the United States; however, care labels 

do not have to be attached to products when they enter the United States. The importer must 

ensure the labels are attached prior to sale. 

Labels must be attached permanently and securely and be legible during the useful life of the 

product and be seen or easily found by consumers at the point of sale. For packaged items, the 

care label must appear also on the outside of the package or on a hangtag if it is not clearly

visible through the packaging.

For more detailed information, see FTC’s:

Clothes Captioning: Complying with the Care Labeling Rule and 

Clothing and Textiles Legal Resources

Pending Regulations of Note

The FTC, in 2012, published in the Federal Register a Notice of Proposed Rulemaking (NPRM)

the Care Labeling Rule. The notice provides specifics as to the amendments under consideration 

and makes a request for comments. See:

Notice of Proposed Rulemaking: Trade Regulation Rule on Care Labeling of Textile Wearing 

Apparel and Certain Piece Goods (September 20, 2012)
Page | 19

United States Department of Agriculture (USDA)

Organic Fibers: Organic Foods Production Act of 1990 (OFPA)

Title 7, United States Code, Chapter 94, ORGANIC CERTIFICATION, Sections 6501-6523

The USDA regulates the term organic as it applies to agricultural products through the National 

Organic Program (NOP) Regulation, 7 CFR Part 205. Raw natural fibers, such as cotton, wool, 

and flax are agricultural products and are covered under the NOP crop and livestock production 

standards. Any textile product produced in full compliance with the NOP regulations, including 

being certified by an approved third party, may be labeled as NOP certified organic and display 

the USDA organic seal. Products produced in accordance with the Global Organic Textile 

Standard (GOTS) may be sold as organic in the U.S., but may not refer to NOP certification or 

display the USDA organic seal. 

For more detailed information, see USDA’s:

Policy Memorandum - Labeling of Textiles That Contain Organic Ingredients and

National Organic Program Handbook

OVERVIEW OF U.S. STATE REGULATORY FRAMEWORKS

A growing number of areas are covered by both state and federal statutes, including consumer 

protection, employment, and food and drug regulation. (State laws give way to stricter federal 

laws that address the same issue.) When a state’s Governor signs a bill, it becomes a state law. 

Once a law has been enacted by a state, it is the responsibility of the appropriate state agency 

to create the regulations necessary to implement the law.

STATE REGULATORY AUTHORITIES AND TECHNICAL REGULATIONS (MANDATORY)

In the U.S., some state laws and regulations are enacted which are more stringent that the 

federal laws. These laws include regulations for products, labeling, packaging, chemical 

restrictions, etc. California and New York are heavily regulated for many consumer products.

Agency/Organization Scope

State Authorities Responsible for Weights and 

Measures

Labeling

Toxics in Packaging Clearinghouse (TPCH) Packaging

International Association of Bedding and 

Furniture Law Officials (IABFLO)

Labeling

California Office of Environmental Health 

Hazard Assessment (OEHHA)

Toxic chemicals
Page | 20

California Bureau of Electronics and Appliance 

Repair, Home Furnishings and Thermal 

Insulation (BEARHFTI)

Plumage, flammability of upholstered 

furniture and bedding

California Department of Consumer Affairs Made in the USA claims

Connecticut Department of Consumer 

Protection

Asbestos in children’s products

Illinois Department of Public Health Lead labeling

Minnesota Department of Commerce Formaldehyde in children’s products

Washington Department of Ecology Lead, cadmium, and phthalates in children’s 

products

Several states Flame retardants, fur labeling, chemicals of 

concern

Packaging and Labeling

UPLR

The Uniform Packaging and Labeling Regulations (UPLR) contained in Uniform Laws and 

Regulations in the areas of Legal Metrology and Engine Fuel Quality, NIST Handbook 130, have 

been adopted into law in 45 of the 50 U.S. states. The purpose of these regulations is to provide 

accurate and adequate information as to the identity and quantity of contents of packages so 

that purchasers can make price and quantity comparisons. 

The UPLR requires that consumer packaging bear a label specifying the identity of the 

commodity; the name and place of business of the manufacturer, packer, or distributor; and 

the net quantity of contents in terms of weight or mass measure, or numerical count in a 

uniform location upon the principal display panel. 

Toxics in Packaging Legislation

This model legislation was originally drafted by the Source Reduction Council of the Coalition of 

Northeastern Governors (CONEG) in 1989. It was developed in an effort to reduce the amount 

of heavy metals in packaging and packaging components that are sold or distributed 

throughout the United States. The law is designed to phase out the use and presence of 

mercury, lead, cadmium, and hexavalent chromium in packaging. The legislation has been 

successfully adopted by nineteen states.

For more detailed information, see Toxics in Packaging Clearinghouse white paper:

Toxics in Packaging Fact Sheet
Page | 21

Uniform Law Label

Filled bedding, apparel and textiles, sleeping bags and toys sold in the United States require a 

special label. Thirty-one states, including California, Massachusetts, New York, Ohio, and 

Pennsylvania, have established laws requiring labeling of bedding and upholstered apparel and 

textiles. In order to simplify compliance with the various state bedding and upholstered 

apparel and textiles labeling laws, the International Association of Bedding and Furniture Law 

Officials (IABFLO), an association made up of state officials responsible for the enforcement of 

bedding and apparel and textiles laws in their respective states, established a uniform law 

labeling system to assist manufacturers.

Law labels must describe the filling materials of the article as a percentage of those filling 

materials by weight. Example: 80% Polyurethane Foam, 20% Polyester Fibers. It also specifies 

that “UNDER PENALTY OF LAW THIS TAG IS NOT TO BE REMOVED EXCEPT BY CONSUMER” 

when used for bedding and apparel and textiles. The products requiring law labels in each state 

vary, as do the labeling requirements. Uniform law labels can be produced to satisfy the 

different requirements of each state.

Law labels are also required in most states to display a Uniform Registry Number which 

identifies the manufacturing facility that produced the product. This can be any company in the 

world whose products are sold in the United States. A law label may NOT be combined with 

another label. However, it is acceptable to have a bold black line between a law label and the 

California flammability label (printed side-by-side to show as two separate labels).

For more detailed information, see

IABFLO’s: Bedding & Furniture and Sample Bedding Label Law

American Law Labels white paper: American Law Label, Inc. (includes applicable 

products and exemptions)

 

State of California

Lead and Other Toxic Substances

California regulates lead and numerous other substances and chemicals, in both adult and 

children's products, through their Safe Drinking Water and Toxic Enforcement Act of 1986, 

more popularly known as Proposition 65 or Prop 65 (California Health and Safety Code. Section 

25249.6, et seq.) There have been several settlements relative to chemicals such as lead, DEHP 

(phthalates), and flame retardants in apparel and textiles. These settlements provide guidelines 

for suggested limits. Prop 65’s List of Hazardous Substances is maintained and updated as new 

chemicals are identified. 
Page | 22

The following warning language is required on products sold in California if they contain 

chemicals on the Proposition 65 list and the amount of exposure caused by the product is not 

within defined safety limits:

WARNING: This product contains chemicals known to the State of California to cause cancer 

and birth defects or other reproductive harm.

For more detailed California official information on Proposition 65, see: 

Office of Environmental Health Hazard Assessment (OEHHA), Proposition 65 in Plain 

Language, and

Also see Prop 65 News

Safer Consumer Products Regulations

The Safer Consumer Product Regulations applies to all consumer products placed in the stream 

of commerce in California. It requires manufacturers or other responsible entities to seek safer 

alternatives to harmful chemical ingredients in widely used products. The regulations require 

the Department of Toxic Substance to adopt regulations that will establish a process for 

identifying and prioritizing chemicals in consumer products and to establish a process for 

evaluating chemicals of concern in consumer products and their potential alternatives.

For more detailed information, see

What are the Safer Consumer Products Regulations?

Plumage Regulations

Article 5 of the Department of Consumer Affairs Bureau of Home Furnishings and Thermal 

Insulation Rules and Regulations sets forth the requirements labeling based on the minimum 

percentage of down and down feathers.

Flammability of Upholstered Furniture and Bedding 

The California Bureau of Electronic and Appliance Repair, Home Furnishings, and Thermal 

Insulation (BEARHFTI) regulates (4 CCR § 1370-1374.3) the flammability of upholstered 

furniture and bedding regardless of its point of origin. These regulations include specific 

testing and labeling requirements which are specified in the regulations and Technical Bulletin 

117-2013 - Requirements, Test Procedure and Apparatus for Testing the Smolder Resistance of 

Materials Used in Upholstered Furniture.
Page | 23

TB117-2013 flammability standard applies to upholstered furniture sold in California. Bedding 

products such as mattresses, comforters, mattress pads, bed pillows as well as decorative 

pillows are not subject to TB117-2013. They must, however, carry a law label.

California Chapter 862, signed into law September 30, 2014, requires a manufacturer of 

covered products, as defined, to indicate on the label whether or not the product contains 

added flame retardant chemicals by including a specified statement on that label. The 

statement must immediately follow the TB 117 labeling requirements on the same label. The 

law also requires manufacturers to retain documentation supporting the information on the 

label.

Currently, several items are exempted under the California Code of Regulation section 1374.2, 

including strollers, infant carriers, and nursing pillows; cushions and pads intended solely for 

outdoor use; and any article which is smooth surfaced and contains no more than one-half inch 

of filling material, provided that such article does not have a horizontal surface meeting a 

vertical surface.

For more detailed information, see BEARHFTIs:

Technical Bulletin 117-2013 Frequently asked Questions (FAQs), 

Rules and Regulations and 

Order of Adoption -- Criteria for Exemptions

Made in the USA

A recent law relaxed California’s strict “Made in USA” Law. Under the revised law “Made in the 

USA”, “Made in America”, “U.S.A” or similar labels are allowed even if a product has some 

foreign components. The labeling is permitted if any foreign component or part does not 

constitute more than 5% of the final wholesale value of the product or any foreign component 

or part does not constitute more than 10% of the final wholesale value of the product AND the 

manufacturer can show that those components cannot be obtained or produced domestically.

Connecticut 

Safe Children’s Products

Beyond federal children’s safety regulations, this Act bans the introduction or delivery for 

introduction into commerce of any toy or other article for sale in the state of Connecticut 

marketed for the use of children under the age of 16 containing asbestos.
Page | 24

State of Illinois

Lead

Public Act 097-0612, The Lead Poisoning Prevention Act

The Act makes it illegal to sell, have, offer for sale, or transfer children’s products that contain a 

total lead content in any component part of the item that is more than 0.004% (40 parts per 

million) but less than 0.06% (600 parts per million) by total weight (or a lower federal or State 

standard for lead content if applicable) unless that item bears a warning statement that 

indicates that at least one component part of the item contains lead. The warning statement 

must contain at least the following: 

"WARNING: CONTAINS LEAD. MAY BE HARMFUL IF EATEN OR CHEWED. COMPLIES WITH 

FEDERAL STANDARDS."

The Act also makes it illegal to sell, or give away any lead-bearing substance that may be used 

by the general public, unless it bears a warning statement as prescribed below, or as 

prescribed by any other federal regulation. The statement shall be located in a prominent 

place on the item or package (16 CFR 1500.121). 

If no regulation is prescribed, the warning statement shall be as follows when the lead-bearing 

substance is a lead-based paint or surface coating:

“WARNING-CONTAINS LEAD. MAY BE HARMFUL IF EATEN OR CHEWED. See Other Cautions on 

(Side or Back) Panel. Do not apply on toys, or other children’s articles, furniture, or interior or 

exterior exposed surfaces of any residential building or facility that may be occupied or used by 

children. KEEP OUT OF REACH OF CHILDREN.” 

If no federal regulation is prescribed, the warning statement shall be as follows when the leadbearing substance contains lead-based paint or a form of lead other than lead-based paint:

“WARNING: CONTAINS LEAD. MAY BE HARMFUL IF EATEN OR CHEWED. MAY GENERATE DUST 

CONTAINING LEAD. KEEP OUT OF REACH OF CHILDREN.” 

The warning statements do not apply to any product for which federal law governs warning in a 

manner that preempts state authority.
Page | 25

Minnesota

Formaldehyde in Children’s Products

Minnesota bans the sale of certain products intended for children aged 8 and under that 

contain intentionally added formaldehyde or ingredients that degrade into formaldehyde. 

Children’s product is defined, for the purpose of this law, as a product primarily designed or 

intended by a manufacturer to be physically applied to or introduced into a child's body, 

including any article used as a component of such a product, excluding a food, beverage, 

dietary supplement, pharmaceutical product or biologic, children's toys (covered by CPSC 

rules), or a medical device (covered by FDA rules).

Washington State

Lead, Cadmium, and Phthalates in Children’s Products

Washington’s Children’s Safe Products Act restricts the sale of children’s products containing 

more than 0.009 percent by weight of lead; more than 0.004 percent by weight of cadmium, or 

0.10 percent by weight of phthalates, individually or in combination. 

The limits and scope of this law is more stringent than the current federal requirements. 

Products included under this Act include children’s cosmetics; jewelry; toys; car seats; and 

childcare articles, including clothing and footwear.

See Washington Department of Ecology’s:

Children’s Safe Products Act Webpage

Multiple States

Flame Retardant Regulations

Several U.S. states have legislation banning the use of flame retardants, such as PentaBDE, 

OctaBDE, DecaBDE, TCEP, and chlorinated tris, in products, including upholstered furniture and 

children’s products. The states include: Hawaii, Illinois, Maine, Maryland, Michigan, Minnesota, 

New York Oregon, Rhode Island, Vermont, and Washington. Legislation has been proposed in 

the following states: Alaska, California, Connecticut, Delaware, Massachusetts, New York, North 

Carolina, Ohio, Rhode Island, and Washington.

Fur Labeling

Delaware, Massachusetts, New Jersey, New York, and Wisconsin have enacted legislation for 

labeling of fur products. Delaware requires that any wearing apparel containing real fur 

(wholly or partially) have attached and conspicuously displayed on the apparel a tag, label or 
Page | 26

sticker that states the product was made with fur. Under Massachusetts law, all natural, dyed 

or imitation furs, and all articles made wholly or partly from them and are sold at retail within 

the commonwealth, shall be plainly marked or labeled with an accurate statement of the 

material which they contain, together with the name and address of the seller. New Jersey 

law requires that any new coat, jacket, garment or other clothing apparel made wholly or in 

part of fur, regardless of the price or value of the fur shall not be sold unless it has attached and 

conspicuously displayed a tag or label including the name of the animal(s) used to produce the 

fur, and the name of the country of origin of any imported fur. New York law makes it illegal to 

sell any faux or real fur product that is not properly labeled. Wisconsin law states that no 

person shall sell or offer or display for sale any coat, jacket or other garment with a value 

over $50 made wholly or partially of fur without a label that states in English the species of

fur or pelt used.

Dog and Cat Fur

In addition to the federal ban, New York State has a similar regulation. It bans the sale of fur, 

skin, hair, or flesh from a dog or cat and requires manufacturers or suppliers to provide 

certification to each retailer that any fur, hair, skin, or flesh contained in such items is not 

derived from domesticated dog or domesticated cat.

Chemicals of Concern

Several states, including Oregon, Washington, Vermont, and Maine, require manufacturers

selling children’s products that contain a chemical that is included on the state’s chemicals of 

concern list to provide notice to the state prior to sale in that state. In some cases, the 

manufacturer must remove or make a substitution for the chemical.

Crib Bumpers

Maryland and the city of Chicago have banned the sale of crib bumper pads. The Maryland 

ban applies to crib bumpers that are made of non-mesh type material, rest directly above the 

mattress along the length of each of the interior sides of the crib, and are intended to be used 

until the age that an infant pulls to stand. Illinois is considering similar legislation.
Page | 27

OVERVIEW OF THE U.S. VOLUNTARY STANDARDS FRAMEWORK

The U.S. system of standards development is driven by the private sector. The majority of U.S. 

standards are voluntary and developed through consensus methods that reflect the needs of 

producers and manufacturers, users and consumers, and the government. The American 

National Standards Institute (ANSI) (a non-governmental, not-for-profit organization) 

coordinates much of the private sector activities of the voluntary standards development 

community in the U.S. There are hundreds of voluntary standards developing organizations in 

the United States responsible for standardization in many different industries and business 

sectors. The National Institute of Standards and Technology (NIST), a part of the U.S. 

Department of Commerce, is the national metrology laboratory for the United States. NIST 

provides the technical measurement infrastructure to support global trade and the commercial 

measurement system. NIST, through its Standards Coordination Office, advises on and 

coordinates federal participation in standards setting.

STANDARDS DEVELOPING ORGANIZATIONS (SDOS) 

American Association of Textile Chemists and Colorists (AATCC)

P.O. Box 12215 

Research Triangle Park, NC 27709-2215 USA

Telephone: +1 919 549 8141

Staff Directory

The American Association of Textile Chemists and Colorists (AATCC) develops test methods and 

evaluation procedures for textiles and apparel. These methods are published each year in the 

AATCC Technical Manual.

Examples of AATCC standards:

Antimicrobial Activity Assessment of Textile 

Materials: Agar Plate Method

Test Method 90

Colorfastness to Crocking. Crockmeter 

Method. 

Test Method 8

Colorfastness to Crocking: Rotary Vertical 

Crockmeter Method.

Test Method 116

Colorfastness to Crocking: Textile Floor 

Coverings-Crockmeter Method

Test Method 165

Colorfastness to Dry-cleaning Test Method 132

Colorfastness to Light Test Method 16

Colorfastness to Perspiration Test Method 15

Colorfastness to Water Test Method 107

Fiber Analysis: Qualitative Test Method 20
Page | 28

Fiber Analysis: Quantitative Test Method 20A

Finishes in Textiles: Identification Test Method 94

Abrasion Resistance of Fabrics: Accelerotor 

Method

Test Method 93

Absorbency of Textiles Test Method 79

Appearance of Apparel and Other Textile End 

Products After Repeated Home Laundering

Test Method 143

Carpets: Cleaning of, Hot Water Extraction 

Method

Test Method 171

Carpets: Electrostatic Propensity of Test Method 134

Stain Resistance: Pile Floor Coverings Test Method 175

Water Resistance: Rain Test Test Method 35

ASTM International

100 Barr Harbor Drive

P.O. Box C700

West Conshohocken, PA 19428-2959 USA

Telephone: + 1.610.832.9500

Staff Directory

ASTM International (ASTM) develops and maintains consensus standards and test methods 

pertaining to apparel and textiles. A number of the ASTM standards or test methods are 

“Incorporated By Reference” in the CFR (as cited above under CPSC), and are mandatory.

The ASTM Committee responsible for apparel and textiles is Committee D13 on Textiles. 

The following ASTM Subcommittees relevant to apparel and household textiles include:

D13.11 Cotton Fibers

D13.13 Wool and Felt

D13.16 Rope and Cordage

D13.17 Flax and Linen

D13.18 Glass Fiber and its Products

D13.19 Industrial Fibers and Metallic Reinforcements

D13.20 Inflatable Restraints

D13.21 Pile Floor Coverings

D13.40 Sustainability of Textiles

D13.51 Conditioning and, Chemical and Thermal Properties

D13.52 Flammability

D13.54 Subassemblies

D13.55 Body Measurement for Apparel Sizing

D13.58 Yarns and Fibers
Page | 29

D13.59 Fabric Test Methods, General

D13.60 Fabric Test Methods, Specific

D13.61 Apparel

D13.62 Labeling

D13.63 Home Furnishings

D13.65 UV Protective Fabrics and Clothing

D13.66 Sewn Product Automation

Examples of ASTM apparel and household textiles standards include:

D1230 Standard Test Method for Flammability of Apparel Textiles

D3691/D3691M Standard Performance Specification for Woven, Lace, and Knit 

Household Curtain and Drapery Fabrics

D5489 Standard Guide for Care Symbols for Care Instructions on 

Textile Products

D276 Standard Test Methods for Identification of Fibers in Textiles 

D629 Standard Test Methods for Quantitative Analysis of Textiles

D4964 Standard Test Method for Tension and Elongation of Elastic 

Fabrics (Constant-Rate-of-Extension Type Tensile Testing 

Machine)

D6614 Standard Test Method for Stretch Properties of Textile Fabrics -

CRE Method

D6797 Standard Test Method for Bursting Strength of Fabrics 

Constant-Rate-of-Extension (CRE) Ball Burst Test

D1230 Standard Test Method for Flammability of Apparel Textiles

D4151 Standard Test Method for Flammability of Blankets

D6413/D6413M Standard Test Method for Flame Resistance of Textiles (Vertical 

Test)

D6545 Standard Test Method for Flammability of Textiles Used in 

Children's Sleepwear

D3690 Standard Performance Specification for Vinyl-Coated and 

Urethane-Coated Upholstery Fabrics-Indoor
Page | 30

TESTING AND CERTIFICATION BODIES

Testing

For apparel and textiles, see the list of Labs Recognized by the CPSC. Labs can be searched by 

product (e.g., apparel) or by scope (e.g., 16 CFR Part 1611, Flammability of Plastic Vinyl Film).

Numerous laboratories test apparel and textiles to recognized industry standards; some may be 

accredited. A listing of accredited testing laboratories can be found at A2LA Listing of 

Accredited Labs by Test. Listings of other testing laboratories can be found at ASTM Directory 

of Testing Laboratories. Search on the keyword ‘apparel and textiles’ or on a specific ASTM 

standard.

Certification

Section 102 of the CPSIA requires every manufacturer or importer of all consumer products 

that are subject to a consumer product safety rule enforced by the CPSC to issue a certificate 

stating that the product complies with the applicable standard, regulation, or ban. The 

certificate must accompany the product and be furnished to the retailer or distributor. Section 

102 also requires the manufacturers or importers of children’s products (age 12 years or 

younger) to certify that the products comply with all relevant product safety standards by 

issuing a children’s product certificate supported by tests performed by a CPSC-accepted thirdparty testing laboratory.

RELEVANT U.S. GOVERNMENT AGENCIES

U.S Customs and Border Protection (CBP)

1300 Pennsylvania Avenue, NW

Washington, D.C. 20229 USA

Telephone: +1.703.526.4200 

Email Online Form

For more detailed information, see the U.S. International Trade Commission’s (USITC):

Harmonized Tariff Schedule of the United States
Page | 31

U.S. Consumer Product Safety Commission (CPSC)

4330 East West Highway

Bethesda, MD 20814 USA

Telephone: +1.301.504.7923

Email Online Form

CPSC Office Telephone

Office of International Programs and Intergovernmental Affairs +1.301.504.7071

Office of Compliance and Field Operations +1.301.504.7915

Deputy Director +1.301.504.7520

Office of Import Surveillance +1.301.504.7677

Environmental Protection Agency (EPA)

Imports Program

2000 Traverwood Drive

Ann Arbor, MI 48105 USA

Telephone: +1.734.214.4100

Fax: +1.734.214.4676

List of Contacts

Federal Trade Commission

600 Pennsylvania Avenue, NW

Washington, DC 20580 USA

Telephone: +1.202.326.2222

List of Contacts

U.S. Department of Agriculture

1400 Independence Avenue, SW

Washington, DC 20250 USA

Telephone: +1.202.720.2791
Page | 32

U.S. APPAREL AND HOUSEHOLD TEXTILES INDUSTRY AND MARKET DATA

Industry Trade Associations

American Apparel and Footwear Association (AAFA)

1601 North Kent Street, 12th Floor

Arlington, VA 22209 USA

Telephone: +1.703.524.1864 and +1.703.522.6741

AAFA is the national trade association in the U.S. that represents apparel, footwear, and other 

sewn products companies and their suppliers. The AAFA publishes in several languages a 

Restricted Substances List (RSL) that provides information related to regulations and laws that 

restrict or ban certain chemicals and substances in finished home textile, apparel, and footwear 

products around the world.

Industrial Fabrics Association International (IFAI)

1801 County Road B W

Roseville, MN 55113-4061 USA

Telephone: +1 651 222 2508 or +1 800 225 4324

The Industrial Fabrics Association International is a not-for-profit trade association comprised of 

member companies representing the international specialty fabrics marketplace.

United States Fashion Industry Association (USFIA)

1140 Connecticut Avenue, Suite 950 

Washington, DC 20036 USA

Telephone: +1 202-419-0444

USFIA, formerly the United States Association of Importers of Textiles & Apparel, provides 

education, information, and advocacy to executives active in textiles and apparel sourcing, 

importing, compliance, and logistics. USFIA represents the needs of American retailers, brands 

and importers, as well as related service providers, with the objective to remove barriers to 

business and to trade.

Apparel and Household Textiles Market Data

American Apparel and Footwear Association (AAFA)

Trends: An Annual Statistical Analysis of the U.S. Apparel and Footwear Industries (2008)

Industry Statistics

Office of Textiles and Apparel (OTEXA)

Trade data: U.S. imports and exports of textiles and apparel
Page | 33

The NIST Standards Information Center makes every effort to provide accurate and complete 

information. Various data such as names, telephone numbers, links to websites, etc. may 

change prior to updating. We welcome suggestions on how to improve this Guide and correct 

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errors or omissions in the Guide or other data. Some of the documents referenced point to 

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does not control and cannot guarantee the relevance, timeliness, or accuracy of these materials.

February 2012/Revised June 2016 

Prepared by the Standards Information Center 

Standards Coordination Office (SCO) 

National Institute of Standards and Technology (NIST) 

standardsinfo@nist.gov

http://www.nist.gov/ncsci