HTSBase
CPSC general useUnited StatesMattresses

Do mattresses need a GCC?

Updated

Short answer

Yes. Crib mattresses need a CPC instead.

Every mattress sold in the U.S. is subject to two Flammable Fabrics Act standards: 16 CFR 1632 (cigarette ignition, which also covers mattress pads) and 16 CFR 1633 (open flame, for mattress sets). Because those are rules CPSC enforces, the importer or U.S. manufacturer must issue a General Certificate of Conformity (GCC) and, since July 8, 2026, eFile its data with each entry. A crib mattress is a children's product and needs third-party testing and a Children's Product Certificate instead.

What changes the answer

  • What is a mattress. 16 CFR 1632.1 includes adult, youth and crib mattresses, futons, bunk bed and trundle mattresses, sofa bed mattresses and air or water mattresses with upholstery between the ticking and core. It excludes sleeping bags, pillows, foundations, pads for strollers and carriers, and air or water beds without upholstery material.
  • Prototype testing. Part 1633 is built on prototype tests. Each model must be tied to a qualified prototype, with records of the prototype tests and of production pooling or confirmation tests.
  • Sold with or without a foundation. The 1633 label must say whether the mattress was tested alone or with a named foundation, and the certification statement changes with it.
  • Roll-packed and compressed mattresses. Bed-in-a-box mattresses are mattresses like any other and must meet both standards.
  • Crib mattresses. These are also durable infant products, subject to the crib mattress standard in 16 CFR 1241, the registration card rule in 16 CFR 1130, and third-party testing.

What to do

  1. Test each prototype to 16 CFR 1632 and 16 CFR 1633, and keep the prototype and production records both parts require.
  2. Attach the permanent label required by 16 CFR 1633.12: manufacturer and importer names, full addresses, month and year of manufacture, model, prototype ID, the certification statement and whether it is intended for use with a foundation.
  3. Issue a GCC citing 1632 and 1633, with the data elements in 16 CFR 1110.11, and eFile it with the entry.
  4. For crib mattresses, test at a CPSC-accepted lab, issue a CPC, add tracking labels and the registration card.
HTS lines for mattresses
  • 9404.21.00.13

    9404: Mattress supports; articles of bedding and similar furnishing (for example, mattresses, quilts, eiderdowns, cushions, pouffes and pillows) fitted with springs or stuffed or internally fitted with any material or of cellular rubber or plastics, whether or not covered

    Mattresses / Of cellular rubber or plastics, whether or not covered / Of a width exceeding 91 cm, of a length exceeding 184 cm, and a depth exceeding 8 cm

    Foam mattresses wider than 91 cm, longer than 184 cm and deeper than 8 cm.

    General rate
    3%
    Free or reduced under 17 programs
  • 9404.29.90.87

    9404: Mattress supports; articles of bedding and similar furnishing (for example, mattresses, quilts, eiderdowns, cushions, pouffes and pillows) fitted with springs or stuffed or internally fitted with any material or of cellular rubber or plastics, whether or not covered

    Mattresses / Of other materials / Of a width exceeding 91 cm, of a length exceeding 184 cm, and a depth exceeding 8 cm

    Mattresses of other materials of the same size, such as hybrid and innerspring.

    General rate
    6%
    Free or reduced under 17 programs
  • 9404.21.00.10

    9404: Mattress supports; articles of bedding and similar furnishing (for example, mattresses, quilts, eiderdowns, cushions, pouffes and pillows) fitted with springs or stuffed or internally fitted with any material or of cellular rubber or plastics, whether or not covered

    Mattresses / Of cellular rubber or plastics, whether or not covered / For use in a crib or toddler bed

    Foam mattresses for a crib or toddler bed.

    General rate
    3%
    Free or reduced under 17 programs

Next steps

Frequently asked questions

Do mattress toppers need a GCC?
A mattress pad, meaning a thin mat or ticking filled with resilient material for use on top of a mattress, is covered by 16 CFR 1632. Foam toppers not fully encased in ticking are excluded from the pad definition. Check your construction against 1632.1.
Can the factory's test report be used for the GCC?
Yes, if it covers the prototype your model is tied to and the factory's records meet 1632 and 1633. As importer you issue the certificate and answer for it.
Do mattresses need a law label too?
Many states have their own bedding law labels and registration. Those are separate from the federal 1633 label and GCC.

Sources

  1. 16 CFR part 1632, Standard for the flammability of mattresses and mattress pads, eCFR, National Archives
  2. 16 CFR part 1633, Standard for the flammability (open flame) of mattress sets, eCFR, National Archives
  3. 16 CFR 1633.12, Labeling, eCFR, National Archives
  4. 16 CFR 1110.11, Certificate content requirements, eCFR, National Archives
  5. 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.