With the school year approaching for parents, back to school retail season is in full swing for many children’s apparel and toy brands. If you are selling clothing or soft goods for kids, you may want to consider common safety standards required by the Consumer Product Safety Commission(CPSC). I know what you’re thinking, “But I’m a small business, not a giant corporation!” You’re right. You probably qualify as a small batch manufacturer, meaning you make less than 75,000 units a year, made less than $1 million in gross income last year, and therefore don’t have to go through rigorous third-party testing for CPSC requirements on flammability and lead. So why talk about regulations and limit your freedom to design? It’s simple: To avoid risk. I’m no Quality Assurance or Compliance expert, but as a designer it’s good to be mindful of the use of your products to protect your customers and your business. So here’s an overview of three major CPSC tests and requirements to keep the wee ones safe.
1) Pull Test & Drawstrings
What’s the risk? Buttons, bows, fringe and other embellishments can be pulled off by little fingers and go straight in their mouth, becoming a choking hazard! Cases of strangulation by jacket hood drawstrings on playground slides have been reported. There are also cases where waist drawstrings on jackets have been caught in moving school bus doors and have dragged children.
What are the Rules?
- No drawstrings on hoods and children’s upper outerwear in sizes 2T to 12
- No toggles, knots, and other attachments at the free ends of waist drawstrings
- No more than 3 inches of a drawstring outside of a casing when the garment is extended to its fullest width
- Clothing made for children ages 3 and under need to be evaluated for potential choking hazards, such as small buttons, rhinestones or sequins
Design Suggestions:
- Machine bar tack trim securely to garments and baby products so they can’t be easily pulled off
- Leave ribbon belts untacked on garments in case they get caught in an escalator so a child can easily escape
- Avoid toggles on drawstrings since they get caught in small gaps on playground equipment such as slides.
- Use velcro, snap, and button closures on jacket hoods instead of drawstrings
- Avoid pom-poms, sequins, and beading. I know they’re cute! But save it for kids 4 and up
- Screen print or embroider patterns and designs on fabric instead
Check out the requirements of ASTM F1816-97, Standard Safety Specification for Drawstrings on Children’s Upper Outerwear “Standard.”
2) Lead Tests & Phthalates
What’s the Risk? Excessive lead in fabric dyes, trim finishes, and surface prints can poison kids! Phthalates are chemical plasticizers used in the production of plastics and paints. There are currently six types of banned phthalates in toys and child care articles that are used to facilitate sleeping, feeding, teething, or sucking.
What are the Rules?
- No more than 100 ppm total lead content in a garment or soft good
- No more than 90 ppm lead in finishes and surface prints
- No more than 0.1 percent of DEHP, DBP, BBP phthalates in products used for sleeping or that can be placed in the mouth
- No DINP, DIDP, and DnOP phthalates
Design Suggestions:
- Use fabrics with organic and vegetable dyes
- Use natural fibers
- Check lead content of hardware including enamel snaps, buckles, and buttons
- Check lead content in non-metal trim and embellishments such as puff prints and screen prints
Check out www.cpsc.gov/lead and www.cpsc.gov/phthalates for more information.
3) Flammability Test & Sleepwear Flammability
What’s the Risk?
Loose fitting sleepwear, thinner fabrics(less than 2.6 oz), and fuzzy fabrics with a pile can ignite and burn quickly from small-open flames. With CPSC 1610 Flammability Standard, a fabric’s relative flammability is determined by considering its surface structure, weight, and content. Sleepwear for children 0-6 months+ and 7 to 14 years are further regulated by CPSC Standards for the Flammability of Children’s Sleepwear.
What are the Rules?
- Plain surface fabrics(with no pile) over 2.6 oz are exempt from flammability testing regardless of fiber content
- Plain and raised surface fabric made of acrylic, modacrylic, nylon, olefin, polyester, wool, or any of those fiber combinations are exempt of testing regardless of weight
- Hats, gloves, shoes, and interlining fabrics are exempt from flammability testing
- Children’s sleepwear must self-extinguish when exposed to a small open-flame ignition source
- Size 9 months or smaller clothing that does not exceed 64.8 centimeters (25.75 inches) in length for a one-piece garment, or 40 centimeters (15.75 inches) in length for a two-piece garment is exempt from sleepwear regulations
Design Suggestions:
- Use plain surface fabric over 2.6 oz such as cotton poplin or interlock
- Avoid sheer fabrics such as rayon skirts and silk scarves
- Avoid 100% cotton fleece and terry cloth fabrics
- Use synthetic blend with natural fibers
Check out the deets about the Flammable Fabrics Act and Flammability of Clothing.
Phew! That’s a lot of rules to remember. Let’s try to make it easier by focusing on what’s important.
Keep in mind that the regulations to consider are determined by the use of your products. For example, hats exclude certain tests such as flammability because they can be removed fairly easily from a child in the case of a fire.
Interpretation of CPSC guidelines is up to individual companies. Larger retail chains or department stores may have more testing guidelines or require use of approved testing facilities, because they are bigger targets for lawsuits than smaller shops. As a small business, the easiest way to ensure your products are safe is by taking precautions while sourcing. The United States have strict standards that keep dangerous materials from production and off the market, so it pays to source domestically. If your components are imported or manufactured overseas, ask your supplier questions.
More Regulations + References:
- Rules Requiring Third Party Testing
- Bureau Veritas: Toys Juvenile Products
- SGS: Chemical Testing
- NIST: Guide US Apparel and HouseholdTextile
- Laws Selling Handmade Clothing
- USCPSC: Selling Compliant Apparel In The United States English
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