Key takeaways
- Size decides the rule: over 6 ft in one dimension and over 24 sq ft is 16 CFR 1630; no side over 6 ft and 24 sq ft or less is 16 CFR 1631. Bath mats and doormats are usually small rugs.
- Both use the same pill test: eight specimens, and at least seven must keep the char 1 in clear of the frame hole.
- A small rug that fails can still be sold with a permanent FLAMMABLE label. A large rug that fails cannot be sold in the US.
- Fire-retardant-treated rugs carry a "T" on the label and are washed ten times before testing.
- The importer issues the certificate. An inspection checks that the goods match the tested construction and carry the right labels; the burn test is a lab job.
Which rugs fall under 1630 and which under 1631
Both standards apply to any finished product made wholly or partly of fabric or related material and used, or likely to be used, as a floor covering exposed to traffic in homes, offices or other places of assembly or accommodation. They apply whatever the fibre and whatever the method of making. Mats and hides within the size limits are included. Resilient floor coverings such as linoleum and vinyl tile are not.
| Product | Size | Rule |
|---|---|---|
| Bath mat, doormat, 2 × 3 ft rug | No side over 6 ft; 24 sq ft or less | 16 CFR 1631 (small) |
| 4 × 6 ft rug | 6 ft is not over 6 ft; exactly 24 sq ft | 16 CFR 1631 (small) |
| 5 × 8 ft, 8 × 10 ft, 9 × 12 ft rugs | One side over 6 ft and over 24 sq ft | 16 CFR 1630 (large) |
| Wall-to-wall carpet; carpet squares laid into larger areas | Assembled size over the limits | 16 CFR 1630 (large) |
A long narrow runner, such as 2.5 × 8 ft (20 sq ft), has one side over 6 ft but an area not over 24 sq ft, so it matches neither definition word for word. Agree with your lab which standard the test and certificate cite.
Out of scope or excluded. CPSC's carpets and rugs FAQ says a rug labelled and intended for outdoor use only is out of scope of both parts. Both standards also let a one-of-a-kind rug, such as an antique, an Oriental or a hide, be excluded from testing under conditions set by the CPSC. A production run of the same design is not one of a kind.
The methenamine pill test
The method is the same in both parts. Only the size scope differs.
| Step | What the lab does |
|---|---|
| Specimens | Cuts eight 9 × 9 in specimens from a representative sample, centred on the most flammable part of the traffic surface |
| Fire-retardant rugs | Washes the sample ten times first (AATCC 124 method, or an approved alternative); hide and wool flokati rugs have their own alternative procedures and care labels |
| Conditioning | Vacuums each specimen, dries it at 105 °C for 2 hours, cools it in a desiccator for at least 1 hour |
| Ignition | Lays the specimen pile-up in a 12 in open-top box under a steel plate with an 8 in hole, and lights a 150 mg methenamine tablet in the centre |
| Result | Measures the shortest distance from the char to the edge of the hole once burning stops |
| Pass | Each specimen passes if the char does not come within 1 in of the hole; the rug passes if at least seven of eight do |
CPSC staff note that untreated shag or fluffy rugs, and rugs with a polyurethane foam cushioning layer, typically fail.
Labels: FLAMMABLE for failing small rugs, T for treated rugs
Small rugs that fail. Under 16 CFR 1631.5 and 1631.34, a small rug that does not meet the acceptance criterion must carry, before it enters commerce, a legible, conspicuous and permanent label stating:
FLAMMABLE (FAILS U.S. DEPARTMENT OF COMMERCE STANDARD FF 2-70): SHOULD NOT BE USED NEAR SOURCES OF IGNITION.
- It may be on the permanent fibre-content label required by the Textile Fiber Products Identification Act, or on a separate permanent label right next to it. A front label counts as next to a back label only if they are directly opposite each other and close to the edge.
- Direct mail, phone and other sales where the buyer cannot see the label before delivery must show the statement in the advertisement.
- Sales samples and swatches carry it too, and it must show on retail packaging if the rug label is hidden.
Large rugs under 16 CFR 1630 have no labelling option. A large rug that fails cannot be sold in the US.
Fire-retardant treatment. A rug that has had a fire-retardant treatment, or is made of treated fibres, must show the letter "T" on its label and invoices. Alumina trihydrate in a backing counts as a fire-retardant treatment, although the washing step is suspended for it.
Certificates, guaranties and records
The US importer certifies imported rugs under 16 CFR 1110. A general-use rug needs a General Certificate of Conformity based on a test or a reasonable testing program. A rug designed or intended mainly for children aged 12 or under needs a Children's Product Certificate based on testing by a CPSC-accepted lab, plus the lead and tracking-label rules; see CPSIA children's products and the CPSC and CPSIA overview.
Suppliers and importers may also issue a guaranty to their customers. The rules define what testing is "reasonable and representative" for each line, or "quality", of rug:
| Rug type | Minimum tests behind a guaranty |
|---|---|
| Handmade or hide (1630.31(d)) | One at the start of production or import, then one per 10,000 sq yd |
| Machine-made (1630.31(c)) | One at the start, one after 25,000 linear yd, then one per 50,000 linear yd |
| Small rugs (1631.32) | One at the start, then one per 25,000 units or sq yd |
| One of a kind (1630.31(e)) | One test of the rug or of an identical sample |
A "quality" is a line alike in all respects that can affect flammability, including fibre, construction, backing, dyes and any treatment. Any failing test becomes the representative test for that quality. Records, including a 6 × 6 in physical sample and the test reports, must be kept in the US for three years.
What it means for rugs made in India
Hand-knotted and tufted rugs from Bhadohi and Mirzapur, and bath mats and rugs from Panipat, are often sold in a size range. One design can fall under both rules:
- Size ranges. A design offered at 2 × 3, 4 × 6 and 8 × 10 ft needs a 1631 result for the small sizes and a 1630 result for the large one. Only the small sizes can fall back on the FLAMMABLE label.
- Backing and latex. A hand-tufted rug is tested with its latex and backing cloth. A change of backing cloth or latex is a change of quality.
- High pile and foam. Shaggy rugs and rugs with a foam underlay are the types CPSC staff say typically fail untreated.
- Fibre swaps. Viscose, cotton, jute and wool burn differently. A report for a wool rug does not cover a wool-viscose version of the same design.
- Mats. Bath mats and doormats usually meet the small-rug definition, so they need a 1631 pass or the FLAMMABLE label.
What an inspection can verify, and what needs a lab
| An inspector at the factory can check | Only a lab can establish |
|---|---|
| Rug sizes against the order, and so which part applies | The pill test result to 1630 or 1631 |
| Fibre, pile height, backing and latex match the construction in the lab report | Fibre composition by analysis |
| FLAMMABLE label wording and position on failing small rugs; "T" on treated rugs | Whether a fire-retardant treatment survives the ten washes |
| Fibre-content and origin labels present and permanent | CPSC-accepted testing for children's rugs |
How Clear To Load checks this in India
On a rug inspection, the inspector measures sampled rugs, compares pile, backing and fibre with the construction named in your lab report, and checks fibre, origin, FLAMMABLE and "T" labels against your order. For new constructions we pull and seal samples for an ISO/IEC 17025-accredited lab you choose or we suggest, through lab testing coordination.
The report arrives within 24 hours with a verdict of Cleared to load, Hold or Not cleared. Certification stays with the importer. Book an inspection to add these checks.