Clothing and textile products imported, manufactured, and sold in the United States are subject to various labeling, flammability, substance, testing, and certification requirements. This guide explains what US brands should know about such requirements for clothing, curtains, pillows, rugs, and other textile products.
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The Textile, Wool and Fur Acts and Rules sets labeling requirements for textile, wool, and fur products such as clothing, cushions, and rugs.
Here are some examples of covered products:
The Textile, Wool, and Fur Acts and Rules exempt several products, such as:
Textile and apparel products to be sold in the United States must be labeled with the following information:
The label of a textile product must indicate the product’s fiber composition. For example, if the textile fiber product is made entirely out of cotton, then the label should read: “100% cotton”.
However, products with different sections that comprise at least two kinds of fibers should have a label that reads, for instance: “Body: 100% silk Sleeves: 90% cotton, 10% nylon”.
Here we list some common textile fibers:
In general, the label must be conspicuous and accessible on the inside or outside the product. The label must also be securely attached to the product.
Label Placement Examples
a. For garments, the label could be attached near the inside center of the neck.
b. For skirts, the label could be placed inside of the waistband.
c. For pillowcases, the label could be attached on the inside close to the open end.
16 CFR Part 423 contains care labeling requirements. It mandates importers and manufacturers of textile wearing apparel, as well as certain piece goods, to include regular care instructions.
16 CFR Part 423 covers textile wearing apparel, which is defined as textile clothing used to cover body parts, such as hosiery.
It also covers certain piece goods, defined as bolts or rolls of textile products meant for making home-sewn textile clothing.
Part 423 exempts head- and hand-protection products, such as footwear, gloves, and headwear.
Importers and manufacturers must affix care labels to their clothing products, and use the terminology specified in Appendix A to Part 423, such as:
They may choose to use the symbol system specified in ASTM Standard D5489-96c on care instructions or care labels instead of the terms specified in Appendix A.
The regulation also permits the combination of symbols and terms, so long as both comply with 16 CFR Part 423.
The Flammable Fabrics Act (FFA) sets requirements concerning the flammability of clothing, fabrics, carpets, and other textile products.
16 CFR Part 1610 sets up flammability testing standards, methods, and performance requirements for textile clothing products. It requires that textiles that have high flammability should not be made into clothing.
Covered products
16 CFR Part 1610 applies to clothing and fabrics that are intended to be made into clothing.
Exempted products
Part 1610 does not apply to certain types of hats, gloves, footwear, and interlining fabrics.
It also exempts from testing the following materials:
a. Plain surface fabrics with a weight of at least 2.6 ounces per square yard
b. Fabric made of acrylic, modacrylic, nylon, olefin, polyester, and wool (or any combination of the mentioned fibers)
Requirements
16 CFR Part 1610 sets forth flammability classification and requirements:
a. Class 1 – Normal flammability: Fabrics are classified as Class 1 if they exhibit “normal flammability” after being tested according to the testing methods specified in section 1610.6. Class 1 fabrics are deemed suitable for clothing.
b. Class 2 – Intermediate flammability: Raised-fiber surface textiles are classified as Class 2 if they exhibit “intermediate flammability” (i.e., a burn time of 4 to 7 seconds). In this case, they are still deemed to be suitable to be used as clothing. Note that Class 2 doesn’t apply to plain surface textile fabric.
c. Class 3 – Rapid and intense burning: Class 3 fabrics exhibit “rapid and intense burning”. These fabrics are deemed dangerously flammable and should not be used for clothing.
16 CFR Part 1611 sets flammability testing standards and procedures for clothing or textile products made of non-rigid, unsupported vinyl plastic film, such as raincoats.
Covered products
Part 1611 covers textile products that are made from vinyl plastic film. Examples of such products include:
Requirements
This standard mandates fabrics made from vinyl plastic film to fulfill specific flammability requirements. For example, plain surface textile fabrics should burn in 3.5 seconds or more.
These are standards concerning the flammability of children’s sleepwear of different sizes. Both standards set fabric testing methods and procedures using small open-flame ignition sources.
Covered products
Part 1615 applies to children’s sleepwear in sizes 0-6X, whereas Part 1616 applies to children’s sleepwear in sizes 7-14. This includes:
Exempted products
Both standard exempt diapers, underwear, and tight-fitting garments.
Requirements
These parts set up testing and labeling requirements for covered products. The following information should be displayed on children’s sleepwear labels:
16 CFR Part 1630 and Part 1631 are flammability standards for carpets and rugs. They cover testing methods and procedures to determine the surface flammability of carpets and rugs using ignition sources, such as lighted matches.
Covered products
The requirements of Part 1630 apply to household carpet products with dimensions greater than 6 feet (1.83 meters) and a surface area greater than 24 square feet (2.23 square meters).
The requirements of Part 1631 apply to carpets and rugs with dimensions and surface areas smaller than those specified in Part 1630.
Exempted products
Both standards exempt from testing one-of-a-kind small rugs and carpets, such as:
Requirements
Besides flammability testing, both 16 CFR Parts 1630 and 1631 require carpets or rugs that have gone through special fire retardant treatment to contain the letter “T” on the label.
Part 1631 requires that carpets and rugs not meeting all the necessary flammability requirements must bear a permanent label with this statement in bold font:
“FLAMMABLE (FAILS U.S. DEPARTMENT OF COMMERCE STANDARD FF 2-70): SHOULD NOT BE USED NEAR SOURCES OF IGNITION”
The General Certificate of Conformity (GCC) is a document that is self-issued by importers or manufacturers of non-children’s products to demonstrate that the products:
a. Have been tested according to the applicable CPSC’s safety standards or regulations; and
b. Comply with the technical and regulatory requirements.
A GCC should include information such as:
a. Product description (product name, model/batch number)
b. Standards that the products comply with (e.g., 16 CFR Part 1630)
c. Contact information of the importer or domestic manufacturer
d. Production information (Place of origin, manufacturing date)
e. Information about the testing agency (where the product is tested)
A GCC is required for products that are covered by the Flammable Fabrics Act – excluding children’s sleepwear and other children’s products, for which a CPC is required. However, these two documents are similar.
These guides specify the labeling requirements for products that are made of leather or imitation leather. They require that manufacturers, importers, or sellers of leather or imitation leather products must provide an authentic product description on the label, regarding the following aspects:
The Consumer Product Safety Improvement Act (CPSIA) regulates products intended to be used by children below 12 years old, including clothing and textile products.
Here are some examples of apparel or textile products that are covered by CPSIA:
Here we list several standards that are relevant to children’s clothing and textile products:
a. 16 CFR Part 1222 – Safety Standard for Bedside Sleepers
b. 16 CFR Part 1228 – Safety Standard For Sling Carriers
d. 16 CFR Part 1226 – Safety Standard For Soft Infant And Toddler Carriers
d. 16 CFR Part 1229 -Safety Standard for Infant Bouncer Seats
To comply with the CPSIA requirements, importers or manufacturers of children’s clothing prepare the following:
a. Tracking Label containing manufacturer’s name, location, date of production, and other information.
d. Valid test reports issued by CPSC-recognized lab, demonstrating that the products comply with applicable safety standards.
Additional requirements might apply, according to the product. For example, warning labels are required for some products.
The CPSC determined that certain consumer products have characteristics whose existence presents a substantial product hazard to the users. It specifies these products and sets out rules and standards for them under 16 CFR Part 1120 – Substantial Product Hazard List.
The CPSC has listed children’s upper outerwear with hood and neck drawstrings in sizes 2T to 12 in Part 1120 – Substantial Product Hazard List because such products present a strangulation hazard to the children.
Importers and manufacturers of such products should make sure that their products comply with the requirements of ASTM F1816-97 Drawstrings on Children’s Upper Outerwear.
The country of origin marking is mandatory for consumer products, and it should be permanently affixed on the product or packaging. The exact placement depends on the product, but it is common to see the country of origin printed on a sewn label inside garments.
Further, the country of origin label should not be covered by any other label to ensure that it is visible at the time of purchase.
Examples
The FHSA regulates household products that contain potentially dangerous substances such as corrosive, reactive, and toxic substances. The FHSA requires labeling to alert consumers about the potential hazards and what they need to do to protect themselves from those hazards.
The FHSA also covers flammable chemicals and fire retardants that are commonly used in the textile industry. Formaldehyde, which is a chemical substance used to increase wrinkle and crease resistance in textiles, is an example of a substance restricted under the FHSA.
You can learn more about this topic in this document.
The Toxic Substance Control Act regulates the manufacture, importation, usage, and disposal of certain substances and the products that contain those substances. Below we explain how the TSCA regulates PFAS and PBT, which are substances that may be found in textile products.
40 CFR Part 705 sets reporting and recordkeeping requirements for PFAS and products containing PFAS.
Generally, manufacturers of PFAS and products containing the same (including textiles) must report to the EPA on the following:
Persons responsible for reporting the above information must also keep records of information submitted to the EPA. This rule applies to substances and products that were made available between January 1, 2011, and November 13, 2023.
PBT substances persist and bioaccumulate in the environment, and are toxic to human health. They are found in consumer products such as textiles.
According to the EPA, decaBDE is a PBT substance that is used as a flame retardant in textiles and upholstered products.
40 CFR Part 751 prohibits the manufacture, processing, and distribution of decaBDE and products containing the same, such as textiles. It also sets recordkeeping requirements.
The USDA enforces national standards regarding organically produced agricultural items for sale in the US. Products that comply with the requirements may display the USDA organic seal and be labeled as “organic”.
Although the scope of the National Organic Program (NOP) includes many other products, in this section we only focus on requirements regarding textiles.
The NOP covers agricultural raw natural fibers, such as:
The NOP sets certification and recordkeeping requirements.
Certification requirements
Persons who wish to receive organic certification should apply for certification from a certifying agent before exporting their organic agricultural products.
Maintaining organic certification requires paying the annual certification fees to, submitting documentary deviations from their organic system plan to, and permit on-site inspections by a USDA-accredited certifying agent.
You can find the full set of certification requirements in 7 CFR Part 205 Subpart E.
Recordkeeping requirements
According to 7 CFR Part 205.103, the NOP requires certified operations to keep records regarding the manufacture, harvesting, and handling, of agricultural products (e.g., textiles) that are, or that are meant to be, sold, labeled, and represented as organic.
Certified farms and companies show that their products, including textiles, are organic by using the USDA Organic Seal, which is an official and federally protected mark.
Products may bear the USDA Organic Seal if they:
a. Contains ingredients that are 100% certified organic; or
b. Contains at least 95% certified organic ingredients
However, products should not bear the USDA Organic Seal if they:
a. Contain at least 70% of certified organic ingredients that are organically produced (they may still use the “Made with Organic [insert 1–3 ingredients]” claim); or
b. Contain less than 70% of certified organic ingredients
You can find more information about the USDA Organic Seal on this page.
ASTM standards are generally voluntary standards that cover a wide range of product categories, including textiles. Some regulations may incorporate these standards by reference, making compliance with them mandatory.
Importers and manufacturers can use ASTM’s standards to achieve product compliance. Here are several ASTM standards relevant to clothing and textiles:
a. ASTM D1230 – Standard Test Method for Flammability of Apparel Textiles
b. ASTM D5489 – Standard Guide for Care Symbols for Care Instructions on Textile Products
c. ASTM D3938-18 – Standard Guide for Determining or Confirming Care Instructions for Apparel and Other Textile Products
d. ASTM D5433-12 – Standard Performance Specification for Towel Products for Institutional and Household Use
e. ASTM D1777-96 – Standard Test Method for Thickness of Textile Materials
f. ASTM D6545-22 – Standard Test Method for Flammability of Textiles Used in Children’s Sleepwear
g. ASTM D4151 – Standard Test Method for Flammability of Blankets
The US Law Label requires certain textile-containing products, such as pillows, to carry labels specifying their filling materials and other information. Several states in the US implement the US Law Label, such as California, Illinois, and Arizona.
The US Law Label applies to all stuffed products that people can sit or lie down on, such as:
Although the law label requirements vary slightly by state, you generally must attach a label to your product and submit the following information:
Note that most states require you to register for a URN.
California Proposition 65 restricts chemicals that are deemed to cause cancer or reproductive harm. Businesses with 10 or more employees must provide warning labels on their products if the product contains any restricted chemical, in an amount above the set limit.
The proposition applies to consumer products including children’s and adult products sold in California, including apparel and textiles.
Here we list some restricted substances that might be contained in textile products:
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Sources: Our articles are written in part based on publicly available information, and our own practical experience relating to product compliance. These are some of the primary sources we use:
Ivan Malloci is a co-founder of Compliancegate.com and is based in Hong Kong. He completed his Ph.D. in Control Systems at Nancy University, during which he contributed to the development of a hot strip mill control system for ArcelorMittal. See Full Bio.
Jen Smith May 14, 2024 at 10:42 pm For women’s clothing, assuming that all of the above requirements are met, (fantastic comprehensive list- thank you!) is there any 3rd party lab testing that is required, or is that more specific to children’s clothing and products?
Fredrik Gronkvist June 2, 2024 at 2:21 pm Hello Jen, Testing is mandatory for children’s clothing. However, there are testing requirements for certain garments that relate to flammability, and also state level restrictions (for example, California Proposition 65).
Sarah Lucier May 10, 2024 at 4:02 pm I have two identical pairs of pants. Same brand, size, color. I bought one of them from a national retailer in Oregon, the other pair came from Missouri via an EBay reseller with all the tags of the same national retailer. The fabric blend is severely different. Why would that happen? Is there laws about blend specifics within states? Oregon’s pair was mainly rayon and polyester and the ones from Missouri were predominantly cotton.
Fredrik Gronkvist June 2, 2024 at 2:23 pm Hello Sarah, The pants could come from two different batches. Maybe they could not procure the same fabric, or they made the change for other reasons.
Morris M Cohen October 7, 2023 at 12:11 am If a Content label on a varsity jacket only states 100% Polyester for the Jacket, and failed to sectionally disclose the sleeves with polyurethane coating, can it still be acceptable under the label for “100% Polyester” since the substrate of the sleeves are still 100% Polyester (with PU Coating).
Guest June 22, 2022 at 6:46 am Instead of saying “Weight” how about the “Balance number” or “Scaling Size or Number”
