HTSBase
CPSC children'sUnited StatesBaby bibs

Do baby bibs need a CPC?

Updated

Short answer

Yes, and phthalate rules apply too.

A bib is made for babies, so it is a children's product that needs third-party testing at a CPSC-accepted lab, tracking labels and a Children's Product Certificate (CPC). A bib also helps feed children 3 and younger, which makes it a child care article. CPSC lists bibs among its examples of child care articles, so the eight-phthalate limit in 16 CFR 1307 applies to every accessible plasticized part.

What changes the answer

  • Material. Fabric bibs of natural or manufactured fibers, untreated except for dyes, are determined not to exceed the lead limit (16 CFR 1500.91), and natural fibers are on CPSC's list of materials that need no phthalate testing. Silicone, PVC, PEVA and coated or laminated backings are not covered by those determinations and need testing.
  • Printed designs. Screen prints, transfers and coatings must meet the 90 ppm lead in paint limit in 16 CFR 1303 and are tested for lead and, if plasticized, phthalates.
  • Snaps and closures. Metal snaps need lead content testing unless they are a metal on the 1500.91 list. Small parts rules in 16 CFR 1501 do not apply to feeding products and children's clothing accessories (1501.3), but loose snaps are still a recall risk.
  • Flammability. If a cloth bib is treated as wearing apparel, the clothing textile standard in 16 CFR 1610 applies. There is no bib-specific CPSC rule, so ask your lab how it scopes the test plan.

What to do

  1. Have a CPSC-accepted lab test lead content in accessible substrates, lead in surface coatings, and the eight phthalates (DEHP, DBP, BBP, DINP, DIBP, DPENP, DHEXP, DCHP) in any plasticized or coated part.
  2. Add 16 CFR 1610 flammability if the lab treats the bib as apparel.
  3. Issue a CPC listing each rule, the lab and test dates, and eFile it with the entry. eFiling has been required since July 8, 2026.
  4. Put permanent tracking information on the bib and its packaging: who made it, where and when, and the batch.
  5. Keep test records and retest on any material or supplier change.
HTS lines for baby bibs
  • 6111.20.60.70

    6111: Babies' garments and clothing accessories, knitted or crocheted

    Of cotton / Other (239)

    Babies' knitted cotton garments and clothing accessories, other. Knit cotton bibs often fall here.

    General rate
    8.1%
    Free or reduced under 14 programs
  • 6209.20.50.50

    6209: Babies' garments and clothing accessories

    Of cotton / Other (239)

    Babies' woven cotton garments and accessories, other.

    General rate
    9.3%
    Free or reduced under 14 programs
  • 3926.20.90.50

    3926: Other articles of plastics and articles of other materials of headings 3901 to 3914

    Articles of apparel and clothing accessories (including gloves, mittens and mitts) / Other

    Plastic clothing accessories, other. Some silicone and plastic bibs are entered here; check rulings.

    General rate
    5%
    Free or reduced under 17 programs

Next steps

Frequently asked questions

Do silicone bibs need phthalate testing?
Silicone is not on CPSC's list of materials exempt from phthalate testing, and colorants or coatings can add plasticizers. Test it, or rely on component testing of the exact silicone compound from your supplier under 16 CFR part 1109.
Is a bib for toddlers up to age 4 a child care article?
The child care article definition covers products to facilitate feeding of children 3 and younger. A bib marketed for ages 0 to 4 still covers that age range, so treat it as a child care article.
Does an exemption from testing remove the CPC?
No. CPSC states that testing determinations do not exempt a product from the limits, and the CPC must still certify compliance.

Sources

  1. Phthalates FAQ, U.S. Consumer Product Safety Commission
  2. 16 CFR 1307.3, Prohibition of children's toys and child care articles containing specified phthalates, eCFR, National Archives
  3. 16 CFR 1307.2, Definitions, eCFR, National Archives
  4. 16 CFR 1500.91, Lead content determinations, eCFR, National Archives
  5. 16 CFR 1501.3, Small parts exemptions, eCFR, National Archives
  6. Certificates of Compliance final rule (eFiling), published January 8, 2025, Federal Register

This is general information drawn from the official sources linked above. It is not legal advice. Rules change and often turn on the facts of your product, so confirm your test plan with an accredited lab and your obligations with qualified counsel before you import or sell.