Product guide · Children's apparel
What testing does children's clothing need?
Short answer: Kids' clothing (12 and under) needs a CPC backed by a CPSC-accepted lab: 16 CFR 1610 flammability for the fabric unless an exemption applies, 100 ppm total lead in non-textile parts like snaps and zippers, and 90 ppm lead in paint for screen prints. Hood and neck drawstrings are banned on children's upper outerwear in sizes 2T–12, and sleepwear has its own stricter standards (16 CFR 1615/1616).
Last verified: October 2026. General information, not legal advice. KidsTestingLabs is an independent directory and guide: we don't test products and never issue or certify Children's Product Certificates. The US importer or US manufacturer is responsible for certifying compliance.
Test plan
Which tests apply to kids' clothing?
| Issue | Rule | What gets tested |
|---|---|---|
| Flammability of clothing textiles | 16 CFR 1610 | Each fabric, unless exempt (see below). Class 3 fabrics can't be used in clothing |
| Children's sleepwear | 16 CFR 1615 (sizes 0–6X), 1616 (7–14) | Stricter flammability tests; tight-fitting and infant garments fall under 1610 instead |
| Total lead (100 ppm) | CPSIA section 101 | Snaps, buttons, zippers, heat-transfer vinyl, metallic threads |
| Lead in paint (90 ppm) | 16 CFR 1303 | Screen prints and painted trims |
| Phthalates (0.1%) | 16 CFR 1307 | Only if the item is a toy or child care article, e.g. plasticized parts on bibs |
| Drawstrings | 16 CFR 1120.3(b) / ASTM F1816-97 | No hood or neck drawstrings in sizes 2T–12; waist and bottom drawstring limits up to size 16 |
| Tracking label | CPSA section 14(a)(5) | Permanent mark on the garment and packaging |
Sources: CPSC: Clothing FAQ, eCFR: 16 CFR part 1610, eCFR: 16 CFR part 1120, CPSC: Drawstrings in Children's Upper Outerwear.
Exemptions
Which fabrics are exempt from 1610 testing?
Testing exemptions, not exemptions from the rule.
- Plain-surface fabrics weighing 2.6 oz per square yard (88.2 g/m²) or more, any fiber.
- Plain or raised-surface fabrics made entirely of acrylic, modacrylic, nylon, olefin, polyester, wool, or a blend of only these, any weight.
- Not covered by 1610 at all: hats that don't cover the neck, face or shoulders; gloves 14 inches or shorter; footwear without hosiery; interlining fabrics.
Your CPC must still list 16 CFR part 1610; CPSC recommends citing the exemption in the testing section. Exposed linings and reversible garments must be tested on both surfaces unless both are exempt. Textiles that are only dyed are also exempt from lead testing (16 CFR 1500.91(d)(7)). Sources: CPSC: Clothing FAQ, eCFR: 16 CFR 1500.91 (lead determinations).
Small parts
Do kids' clothes need small-parts testing?
No for ordinary clothing: 16 CFR 1501.3(d) exempts children's clothing and accessories, such as shoe lace holders and buttons, from the small-parts ban. Some marketplaces still list it “as applicable” (Amazon's children's sleepwear page, for example), so check items with attached toys or accessories. Sources: eCFR: 16 CFR part 1501 (small parts), Amazon Seller Central: Children's sleepwear.
Cost
How much does kids' clothing testing cost?
Published estimates; labs quote per fabric, component and color.
| Test | Typical unit | Estimate |
|---|---|---|
| 16 CFR 1610 flammability | per fabric composition | $150–$400 |
| Total lead in substrate | per component | $50–$150 |
| Lead in paint (16 CFR 1303) | per color | $75–$200 |
| Sleepwear flammability (1615/1616) | per fabric composition | $500–$1,500 |
Source: EnforceIntel cost table (vendor estimate, Aug 2026). A simple cotton tee with one screen print needs fewer tests than a fleece hoodie with snaps, a zipper and a multi-color print.
How to do it
How do I get a kids' clothing line tested?
- Group styles by fabric and trim so one fabric test can cover several styles.
- Check exemptions (weight, fiber) and keep the fabric specs.
- Book a CPSC-accepted lab accepted for 16 CFR 1610 and the lead methods; check on the CPSC lab search.
- Remove hood and neck drawstrings on outerwear in sizes 2T–12.
- Issue a CPC for each style and add the tracking label to the care label and packaging.
- Check marketplace rules, for example TikTok Shop Kids’ Fashion and Walmart.
FAQ
Frequently asked questions
Do I need to test 100% cotton fabric for lead?
No. CPSC determined that dyed natural-fiber textiles don't exceed the lead limit (16 CFR 1500.91(d)(7)). Prints, snaps and other trims still need testing.
Does 100% polyester fleece need 1610 testing?
No testing is required for fabrics made entirely of polyester (or acrylic, modacrylic, nylon, olefin, wool), but you still certify to 16 CFR 1610 on the CPC.
Can kids' hoodies have drawstrings?
Not at the hood or neck in sizes 2T–12. Waist and bottom drawstrings on upper outerwear up to size 16 must meet ASTM F1816-97 limits.
Are pajamas treated differently?
Yes. Children's sleepwear must meet 16 CFR 1615 or 1616 unless it qualifies as tight-fitting or an infant garment, which fall under 1610.
Do kids' clothes need phthalate testing?
Only if the item is a children's toy or a child care article, such as plasticized parts on bibs. Ordinary daywear isn't covered by that definition.
Next step
Need a CPC or a lab report?
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Sources
Official sources we checked
Checked October 2026. Rules and marketplace policies change; confirm on the source before you act.