CPSIA for children’s clothing: testing, certificates and labels for the US market

Clothing designed or intended primarily for children aged 12 or under is a children's product under US consumer product safety law. That brings four duties: test it at a laboratory accepted by the Consumer Product Safety Commission (CPSC), issue a Children's Product Certificate (CPC) based on those tests, sew a permanent tracking label into it, and, for imports, file the certificate data electronically with US Customs and Border Protection (CBP) at entry, which became mandatory on 8 July 2026. Below: which rules apply to ordinary clothing, which apply only to certain items, and how to fit testing into sampling.

What counts as a children's product

The Consumer Product Safety Act defines a children's product as a consumer product designed or intended primarily for children 12 years of age or younger. The CPSC's rule at 16 CFR 1200 lists four factors it weighs when deciding a case: what the manufacturer says about intended use, including the label, if that statement is reasonable; how the product is shown in packaging, display, promotion and advertising; whether consumers commonly recognise it as intended for a child of 12 or under; and the CPSC staff's Age Determination Guidelines.

Babygrows, toddler sets and primary school shirts are plainly in scope. The grey zone is the top of the size range: a size 14 to 16 hoodie in a teen range may or may not be a children's product, and the rule says the decision is made case by case. If a style sits on that line, ask your lab or a lawyer before treating it as out of scope. The same question arises for school uniforms that span primary and secondary sizes.

The Children's Product Certificate

The CPC is a written statement that the product complies with every children's product safety rule that applies to it. The CPSC says it is issued by the domestic manufacturer or the importer, so for clothing made in Bangladesh it is normally the US brand as importer. The factory and the lab supply the evidence; the certificate is yours.

The CPSC lists seven elements every CPC must contain:

1. Identification of the product covered by the certificate.
2. A citation to each CPSC children's product safety rule the product is certified to.
3. Identification of the domestic manufacturer or importer certifying compliance.
4. Contact details for the person who keeps the test records.
5. Date and place of manufacture.
6. Date or dates, and place or places, of testing.
7. Identification of the CPSC-accepted third-party laboratory that did the testing.

The CPSC also says the certificate and supporting test records must be in English. Under 16 CFR 1107 you must keep the CPC, the test records (separately for each manufacturing site), your periodic testing records and records of any material change for five years, and make them available to the CPSC on request. Item 5 means you must know exactly which factory made the order.

eFiling: certificates at the border since 8 July 2026

Under the CPSC's final rule on certificates of compliance, importers of most regulated consumer products must file certificate data electronically with CBP at entry. The dates:

• 8 July 2026 for most imported consumer products, which includes children's clothing.
• 8 January 2027 for products imported into a Foreign Trade Zone and then entered for consumption or warehousing.

There are two ways to file. A Full PGA Message Set sends the certificate data through CBP's system with each entry; the CPSC lists seven required data elements: product ID, citation codes, manufacture date, manufacture place, product test date, testing laboratory and point of contact. A Reference PGA Message Set lets you store the certificate in the CPSC's Product Registry once and send only three identifiers with the entry: certifier ID, product ID and version ID. Agree the method with your customs broker before your first shipment. Our guide to importing clothes from Bangladesh covers the rest of the entry paperwork.

The rules that apply to children's clothing

Not every CPSC rule applies to every garment. These are the ones a kidswear brand meets most often.

Lead: fabric is exempt, trims and prints are not

The total lead limit for children's products is 100 parts per million in any accessible component part. The CPSC has determined, in 16 CFR 1500.91, that some materials never exceed the limit, so they do not need lead testing. For clothing, the important ones are:

• Textiles made of natural fibres, such as cotton, linen, silk and wool, or manufactured fibres, such as polyester, nylon, rayon, lyocell, acrylic and spandex, dyed or undyed.
• Stainless steel within a stated range of grades (not the leaded grade 303Pb), and precious metals such as gold of at least 10 karat and sterling silver.

The textile exemption excludes any textile with treatments or applications that are not entirely dyes, and the ink exemption excludes screen prints, transfers and decals. So a plain dyed cotton jersey is covered, but the print on it is not. These parts still need testing:

• Metal and plastic trims: zips, zip pullers, snaps, press studs, rivets, buckles, eyelets and plastic buttons.
• Screen prints, heat transfers, heat transfer vinyl, glitter, flock and foil. The CPSC treats screen-printing inks as subject to the 90 ppm lead-in-paint limit of 16 CFR 1303.
• Painted or coated trims, such as enamelled buttons or coated zip pullers, also under the 90 ppm limit.
• Metallic threads and fibres, which the CPSC names as subject to the 100 ppm total lead limit.

An exemption stops applying if a material is treated or adulterated in a way that could add lead, so keep fabric and trim specifications in your certificate file.

Phthalates: in scope only for some garments

The phthalates rule at 16 CFR 1307 limits eight phthalates to 0.1% each in accessible plasticised component parts, but only in children's toys and child care articles. A child care article is a product that helps children aged 3 and under to sleep or feed, or with sucking or teething. The CPSC's clothing guidance names bibs and sleepwear for that age group as examples. Most garments, such as a toddler t-shirt or a school polo, are neither, so the rule does not apply to them. Where it does apply, the parts to watch are plasticised ones: plastisol prints, PVC-backed bib panels and soft plastic appliqués. The CPSC exempts untreated and unfinished fibres from phthalate testing, but that exemption does not cover a print or coating on top.

Flammability: 16 CFR 1610 and the sleepwear rules

16 CFR 1610 applies to all wearing apparel except hats that do not cover the neck, face or shoulders, gloves up to 14 inches long, footwear not attached to a garment, and interlining fabrics. It sorts fabrics into classes by how they burn. Class 1 is normal flammability and acceptable for clothing; Class 3 fabrics burn rapidly and intensely and must not be used in clothing at all.

The standard exempts two groups of fabric from testing: plain surface fabrics weighing 2.6 ounces per square yard (88.2 g/m²) or more, whatever the fibre, and plain or raised surface fabrics made entirely of acrylic, modacrylic, nylon, olefin, polyester or wool, or any mix of those fibres. The CPSC stresses that these are testing exemptions, not exemptions from the rule. Your CPC must still cite 16 CFR 1610, and the CPSC recommends noting the exemption you relied on. Fabrics outside both groups, such as a cotton voile under 88.2 g/m² or a brushed cotton fleece, need testing. The fabric and GSM guide explains how weight is specified.

Children's sleepwear is much stricter. Nightgowns, pyjamas, robes and similar items in sizes 0 to 6X fall under 16 CFR 1615, and sizes 7 to 14 under 16 CFR 1616. Fabrics and certain garments are tested as produced and again after 50 wash and dry cycles. Two exceptions apply:

• Infant garments: sized 9 months or smaller, within set length limits (a one-piece no longer than 64.8 cm), meeting 16 CFR 1610, and labelled with the size in months.
• Tight-fitting garments: within maximum chest, waist, seat, arm, thigh, wrist and ankle dimensions for each size, and carrying a yellow hangtag of a set size and wording stating that the garment should fit snugly and is not flame resistant.

Garments meeting an exception are tested to 16 CFR 1610 like other clothing. If you plan loose-fitting children's pyjamas, talk to your lab before you order fabric.

Drawstrings, small parts and tracking labels

Drawstrings. Under 16 CFR 1120, children's upper outerwear, meaning garments such as jackets and sweatshirts worn over other clothes, is a substantial product hazard if it does not meet ASTM F1816-97. In practice:

• No hood or neck drawstrings in sizes 2T to 12 or the equivalent. The CPSC suggests snaps, buttons, hook-and-loop tape or elastic instead.
• Waist and bottom drawstrings in sizes 2T to 16 may extend no more than 3 inches outside the channel with the garment expanded to its full width, must have no toggles, knots or other attachments at the free ends, and must be bar tacked if they are one continuous string.
• Trousers, shorts and skirts are outside the scope of the standard.

The CPSC says this 15(j) rule does not itself trigger third-party testing or certification. You must still comply, and the garment still needs its CPC for the other rules. Put the drawstring limits in the tech pack and measure them at final inspection.

Small parts. The small parts rule at 16 CFR 1501 applies to toys and other articles for children under 3, but 16 CFR 1501.3 lists children's clothing and accessories, including buttons, as exempt. A snap that comes off a bodysuit is still a choking risk, so set your own pull-strength standard for babywear snaps and buttons. If a garment comes with a separate toy, ask your lab whether that item is assessed as a toy.

Tracking labels. Section 14(a)(5) of the Consumer Product Safety Act requires permanent, distinguishing marks on the product and its packaging, where practicable, that show the manufacturer or private labeler, the location and date of production, and batch or run information. The CPSC says hangtags and adhesive labels are not permanent for textile products, so on clothing the tracking information belongs on a sewn-in label that lasts the life of the garment when the care instructions are followed. It can share the care label; our care label guide covers what else that label carries.

Third-party testing and what drives the cost

Testing for the CPC must be done by a third-party lab that the CPSC has accepted for each specific rule. The CPSC publishes a lab search that you can filter by country, including Bangladesh, and by test scope. Check that its acceptance covers every rule on your certificate.

Ask two or three labs to quote from your bill of materials. What makes a programme larger:

• Number of distinct trims and prints. Each zip, snap, button, print ink and transfer that is not covered by an exemption needs lead testing. Ten styles sharing one snap cost less to test than ten styles with ten different snaps.
• Fabrics outside the 1610 testing exemptions.
• Sleepwear, tested before and after 50 laundering cycles.
• Phthalates, where a garment is a child care article with plasticised parts.
• Factories. The CPSC requires separate certification test records for each manufacturing site, so the same style made in two factories needs two sets.
• Failures, which mean new samples and a retest.

16 CFR 1107 also allows component part testing under 16 CFR 1109, so a trim supplier's results can support your certificate if that rule's conditions are met.

How to plan testing into sampling

The CPSC requires testing on samples of the product, or samples identical to it in all material respects. Test at the right sample stage and bulk is not held up; test at the end and a failure lands on finished goods. A workable order:

1. At development, list every component in the tech pack with its material and supplier, and mark which exemption, if any, applies to each. Design out hood drawstrings and check sleepwear fit and fabric at this point.
2. At trim and print approval, send the approved zips, snaps, buttons, print inks and transfers to the lab for lead testing. Results can then arrive before bulk cutting.
3. At the pre-production sample, when bulk fabric and trims exist, submit the samples for any flammability and phthalate tests. Our guide to garment sample types explains where the PP sample sits.
4. Before shipment, confirm the tracking label on the bulk garments matches the lot, check drawstrings and trims at final inspection, issue the CPC and give your customs broker the data for eFiling.

After the first certificate, 16 CFR 1107 requires periodic testing: at least once a year as standard, at least every two years if you run a production testing plan, and at least every three years if you also test through an ISO/IEC 17025 accredited lab. A material change, including a change of component supplier, that could affect compliance means new third-party tests and a new CPC before you certify again. Tell your supplier that no trim, ink or fabric may be swapped without your approval. Our garment inspection checklist shows where those checks fit, and our quality control service runs checks during production and an AQL final inspection before shipping.

What to do next

Send us the tech pack and bill of materials for your kidswear range. We are a buying house in Narayanganj, Dhaka; orders are made in audited partner factories that we name in writing, with their address, before production, which gives you the place of manufacture for your certificate and tracking labels. Minimums start at 500 pieces per style and colour. See our kidswear manufacturing page and guide for US brands, then request a quote. We reply within one working day. Confirm the rules for your own products with your testing lab or a US compliance lawyer, since this guide describes the rules but is not legal advice.