Key takeaways
- Every fabric used in US apparel must not be Class 3. The standard applies whether or not a test was done.
- Plain-surface fabric of 2.6 oz/yd² (about 88 g/m²) or more, and fabric made only of acrylic, modacrylic, nylon, olefin, polyester or wool, is exempt from testing.
- Light cotton and viscose, and brushed or pile fabrics such as fleece, are the ones that need testing.
- Adult apparel needs a GCC unless it relies on the testing exemption; children's apparel needs a CPC based on a CPSC-accepted lab.
- An inspection can check fibre labels, fabric weight and surface type against the claim; the burn test needs a lab.
What 16 CFR 1610 covers
16 CFR 1610 sets methods for testing the flammability of clothing and of textiles intended for clothing, establishes three classes of flammability, and bans textiles whose burning makes them unsuitable for apparel. It applies to fabric in a form ready for use in wearing apparel, and to garments and costumes finished for consumer use. The current text dates from 2008, amended in 2023.
| Not covered (1610.1(c)) | Exempt from testing (1610.1(d)) |
|---|---|
| Hats, unless they cover the neck, face or shoulders | Plain-surface fabrics of any fibre weighing 2.6 oz/yd² or more |
| Gloves up to 14 inches long not attached to another garment | Plain or raised-surface fabrics made entirely of acrylic, modacrylic, nylon, olefin, polyester or wool, or a mix of only these |
| Footwear, unless it includes hosiery or is attached to another garment | |
| Interlining fabrics used between shell and lining |
Children's sleepwear has its own stricter standards in 16 CFR 1615 and 1616 and is not covered by this guide.
The test and the three classes
A 50 × 150 mm (2 × 6 in) specimen is mounted in a frame at 45°. Raised-surface fabrics are brushed first. A standard flame is applied near the lower end for one second, and the time for the flame to travel 127 mm (5 in) is recorded. For raised surfaces the lab also notes whether the base fabric ignites or fuses. Every textile is tested in its original state and again after refurbishing (dry cleaning and laundering).
| Class | Plain-surface fabric | Raised-surface fabric (pile, nap, tufting, flocking) |
|---|---|---|
| Class 1, normal flammability: acceptable | Burn time 3.5 seconds or more | Burn time over 7.0 seconds, or 7.0 seconds or less with surface flash only and no base burn |
| Class 2, intermediate: acceptable | Not applicable | Burn time 4.0 to 7.0 seconds with base burn |
| Class 3, rapid and intense burning: not acceptable | Burn time under 3.5 seconds | Burn time under 4.0 seconds with base burn |
Certificates and who issues them
Under 16 CFR 1110 the US importer issues the certificate for imported garments, lists 16 CFR 1610 on it, and since 8 July 2026 eFiles the data at entry. See the CPSC and CPSIA overview.
- Adult apparel needs a General Certificate of Conformity based on a test or reasonable testing program. Under a 2016 enforcement policy (81 FR 12587), CPSC does not enforce the certificate requirement for adult apparel that relies on the 1610.1(d) testing exemption. The garment must still comply, and the policy does not cover garments that only partly meet the exemption.
- Children's apparel (for ages 12 and under) needs a Children's Product Certificate based on testing by a CPSC-accepted lab, plus lead, tracking-label and other children's rules. The enforcement policy does not apply. See CPSIA children's products.
What it means for garment exporters in Tiruppur, Ludhiana and elsewhere
For cotton knitwear from Tiruppur, woollens and hosiery from Ludhiana, and garments, scarves and stoles from other Indian clusters, the exemptions decide how much testing is needed:
- Light plain fabrics. Cotton, viscose, linen and silk below 2.6 oz/yd² (about 88 g/m²), such as voiles, muslin, light jersey and georgette, are not exempt and need tests.
- Raised surfaces. Brushed fleece, terry, velour and other pile or napped cotton and viscose fabrics are not exempt by weight. Raised surfaces are classed on surface flash and base burn, so they need testing unless made only of exempt fibres.
- Blends. The fibre exemption applies only to fabric made entirely of the listed fibres. Wool with viscose, or cotton with spandex, is not covered by it, though a plain blend can still qualify by weight.
- Linings and trims. Exposed linings are assessed in their own right; an exempt shell does not cover a lining that is not.
- Finishes. Brushing or peaching can turn a plain fabric into a raised-surface one, and finishes can change burning behaviour. A report on greige or unfinished fabric may not represent the shipped garment.
What an inspection can verify, and what needs a lab
| An inspector at the factory can check | Only a lab can establish |
|---|---|
| Fibre-content labels match the approved specification and the exemption claimed | Burn time and class, before and after refurbishing |
| Fabric weight by GSM cut against the 2.6 oz/yd² threshold, where you rely on it | Actual fibre composition |
| Surface type: plain, brushed, pile or napped, against the tested fabric | Whether a finish or new fabric lot changes the class |
| Fabric lot, colour and finish match the lab report; tracking labels on children's garments | CPSC-accepted testing for a CPC |
How Clear To Load checks this in India
On a pre-shipment inspection in India for apparel, the inspector checks care and content labels, measures fabric weight where you rely on the weight exemption, and records surface type and fabric lots against your lab reports. For new fabrics or children's ranges we pull and seal samples for an accredited lab you choose, CPSC-accepted for children's goods, through lab testing coordination.
The report arrives within 24 hours with a verdict of Cleared to load, Hold or Not cleared. Certification remains the importer's responsibility. Book an inspection to add these checks.