Getting Ready for the CPSIA’s GCC Requirement for Flammability for Clothing Textiles

If you manufacture or import adult clothing, you may not be following the Consumer Product Safety Improvement Act’s (CPSIA) developments closely. Since it is mostly considered a law that impacts children’s products, it seems that those who manufacture or import products for adults think it is not relevant.

But you would be wrong.

And you may not know that the Consumer Product Safety Commission (CPSC) has lifted the stay of enforcement on certification for compliance with the flammability for certain ADULT products – vinyl plastic film, clothing textiles and carpets and rugs. So, effective January 26, 2011, manufacturers must certify compliance for non-children’s products subject to the CPSC regulations pertaining to vinyl plastic films, carpets and rugs, and clothing textiles.

What this means is that for subject products manufactured after January 26, 2011, the manufacturer (or importer) must provide general conformity certificates (GCC) certifying that the products meet their respect requirements – for carpets and rugs, 16 CFR parts 1630 and 1631; for vinyl plastic film, 16 CFR part 1611; and for wearing apparel, 16 CFR part 1610. In other words, every manufacturer of a non-children’s product (and the private labeler of such product if the product bears a private label) subject to regulations pertaining to carpets and rugs, vinyl plastic film, or wearing apparel, whose product is imported for consumption or warehousing or distributed in commerce must issue a GCC for that product.

So, for wearing apparel, non-children’s products manufactured after January 26, 2011 must not only meet the requirements of 16 CFR part 1610 but the manufacturer must issue GCCs certifying compliance to that standard.

What are the requirements?

Well, fifrst, the requirements apply to clothing and textiles intended to be used for clothing. Gloves, hats, footwear and interlining fabrics are generally exempt. Also, plain surface fabrics, regardless of fiber content, weighing 2.6 ounces per square  yard or more are exempt. So, a  manufacturer can issue a GCC certifying this exemption applies. Also exempt are all fabrics, both plain surface and raised-fiber surface textiles, regardless of weight, made entirely from any of the following fibers or entirely from combination of the following fibers: acrylic, modacrylic, nylon, olefin, polyester or wool.

If none of these exemptions apply, then the manufacturer must be able to certify compliance with the standard.

And if you are manufacturing children’s products subject to this regulatiosn, you are not home free. Those already required third party testing. In fact, the CPSC issued this notice of lifting the stay to clarify its position with respect to non-children’s products subject to CPSC regulations pertaining to carpets and rugs, vinyl plastic film, and wearing apparel. The CPSC previously issued a notice lifting the stay for children’s products subject to CPSC regulations pertaining to carpets and rugs, vinyl plastic film and wearing apparel, but many were confused whether non-children’s products were included.

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