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CPSC children'sUnited StatesKids clothing

Does kids clothing need a CPC?

Updated

Short answer

Yes.

Clothing designed or intended primarily for children 12 and under is a children's product. The importer or U.S. manufacturer must issue a Children's Product Certificate (CPC) based on tests at a CPSC-accepted third-party lab, put tracking labels on the garment and packaging, and, since July 8, 2026, eFile the certificate data with the customs entry. Some materials are exempt from testing, but not from the limits or the certificate.

What changes the answer

  • Flammability. Clothing textiles must meet 16 CFR 1610. Plain-surface fabrics of 2.6 oz per square yard or more, and fabrics made entirely of acrylic, modacrylic, nylon, olefin, polyester or wool, are exempt from testing under 1610.1(d). The CPC should still list part 1610.
  • Lead. Accessible parts may not exceed 100 ppm total lead, and paint or surface coatings 90 ppm (16 CFR 1303). Dyed or undyed textiles without other treatments are determined not to exceed the lead limit under 16 CFR 1500.91, so the test load usually falls on zippers, snaps, buttons, screen prints and other coated parts.
  • Sleepwear. Pajamas and robes in sizes above 9 months through 14 are children's sleepwear under 16 CFR 1615 and 1616 and must be flame resistant, unless they meet the tight-fitting or infant garment definitions.
  • Drawstrings. Children's upper outerwear in sizes 2T to 16 with drawstrings that do not meet ASTM F1816-97 is a substantial product hazard under 16 CFR 1120.3. Hood and neck drawstrings are not allowed in sizes 2T to 12.
  • Age. A garment sized and marketed for teens and adults is general use, even if some children wear it. Size range and marketing decide it, under 16 CFR 1200.2.

What to do

  1. List the rules that apply: 16 CFR 1610 (or 1615 and 1616 for sleepwear), lead content, lead in paint, and the drawstring hazard rule as a design check.
  2. Send samples to a CPSC-accepted lab for each applicable test. Use component part testing under 16 CFR part 1109 for trims shared across styles.
  3. Issue the CPC with the data elements in 16 CFR 1110.11, citing each rule and the lab, and eFile it in ACE or by Product Registry reference with the entry.
  4. Add permanent tracking information to the garment and packaging: manufacturer or private labeler, date and place of production, and batch or run number.
  5. Retest on a material change and at the periodic intervals in 16 CFR part 1107.
HTS lines for common kids garments
  • 6109.10.00.14

    6109: T-shirts, singlets, tank tops and similar garments, knitted or crocheted

    Of cotton / Men's or boys' / Other T-shirts / Boys' (338)

    Boys' cotton knit T-shirts.

    General rate
    16.5%
    Free or reduced under 14 programs
  • 6109.10.00.45

    6109: T-shirts, singlets, tank tops and similar garments, knitted or crocheted

    Of cotton / Women's or girls' / T-shirts / Girls' (339)

    Girls' cotton knit T-shirts.

    General rate
    16.5%
    Free or reduced under 14 programs
  • 6111.20.20.00

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

    Of cotton / T-shirts, singlets and similar garments, except those imported as parts of sets (239)

    Babies' cotton knit T-shirts and similar garments.

    General rate
    14.9%
    Free or reduced under 14 programs

Next steps

Frequently asked questions

Do I need to test 100% cotton kids T-shirts for lead?
The fabric, no: dyed cotton is covered by the 16 CFR 1500.91 determination. Screen prints, heat transfers, buttons and snaps are not covered and need lead testing. The CPC still has to certify lead compliance.
Is a size 14 shirt a children's product?
Usually yes, if it is sized and marketed for children 12 and under. Youth sizes that overlap with teen and adult sizes need a closer look at labeling, marketing and the CPSC age determination guidelines.
Can my supplier's lab report replace the CPC?
No. The CPC is issued by the importer or U.S. manufacturer and must cite tests from a CPSC-accepted lab. A supplier's report can be the basis for it if the lab is accepted and the samples match.

Sources

  1. Clothing FAQ, U.S. Consumer Product Safety Commission
  2. 16 CFR part 1610, Standard for the flammability of clothing textiles, eCFR, National Archives
  3. 16 CFR 1500.91, Lead content determinations, eCFR, National Archives
  4. 16 CFR 1120.3, Products deemed to be substantial product hazards, eCFR, National Archives
  5. 16 CFR 1110.13, Certificate availability and eFiling, 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.