PortCert
Questions · Which rules apply

Do children’s clothes need a CPC, and which tests apply?

Yes. Clothing for children 12 and under needs a CPC. The usual rules are total lead content, lead in paint for coatings and prints whose ink scrapes off, and clothing flammability. Dyed or undyed textiles are excluded from lead testing and many fabrics from flammability testing, but each rule is still listed. Sleepwear and drawstrings add rules.

The usual rule list

RuleCoversExclusion often claimed
15 U.S.C. 1278a, total lead contentFabric, snaps, zippers, buttonsTextiles, dyed or undyed, without non-dye treatments 16 CFR 1500.91(d)(7)
16 CFR part 1303, lead in paintPaint, coatings, and screen prints whose ink scrapes off CPSC lead in paint FAQInk that fuses with the fabric is tested with it for total lead instead; ink absorbed like a dye counts as dyed fabric CPSC FAQ
16 CFR part 1610, clothing flammabilityEvery garmentPlain-surface fabric of 2.6 oz/yd² or more, or fabric made only of certain fibers 16 CFR 1610.1(d)

That is the list on CPSC’s own example CPC for a screen-printed baby bodysuit, which names the 1610.1(d)(1) and 1500.91(d)(7)(i) exclusions in place of tests. CPSC adds that no lab is needed to decide whether an exclusion applies; the certifier can assess it CPSC example CPC.

Rules that depend on the garment

  • Sleepwear: part 1615 up to size 6X and part 1616 for sizes 7 to 14 replace part 1610, unless the garment is tight-fitting — or, up to 9 months, an infant garment — as those rules define it 16 CFR 1615.1(a) 16 CFR part 1616. CPSC staff also applies the phthalates rule to sleepwear CPSC example CPC, a rule that covers products helping children 3 and younger sleep 16 CFR 1307.2.
  • Upper outerwear in sizes 2T to 16 with drawstrings that do not conform to ASTM F1816-97 is deemed a substantial product hazard 16 CFR 1120.3(b).
  • Buttons and other clothing accessories are exempt from the small-parts rule 16 CFR 1501.3(d).

Labels, and the adult exemption that does not apply

Tracking labels on textiles must be permanent; CPSC says hangtags and adhesive labels do not qualify CPSC tracking label FAQ. The enforcement discretion CPSC grants to adult garments in exempt fabrics does not reach clothing that is a children’s product CPSC GCC rules list.

How PortCert handles this

We check each component — fabric, print, trims, fasteners — against these rules, claim only the exclusions the regulation allows, and write the CPC and Registry import file: $79 per product, 2 U.S. business days. A garment in several sizes and colors, made and tested together, is usually one product Registry FAQ, Q12.

Get the free check Sample: a children’s pajama set

Last reviewed: October 29, 2026 · First published: September 30, 2026 · Not legal advice.

Sources read October 29, 2026

  1. 16 CFR 1500.91(d)(7) — Lead content determination for textiles
  2. CPSC, FAQ: Lead in Paint (textile screen-printing inks)
  3. 16 CFR 1610.1(d) — Exemptions from testing
  4. CPSC, example CPC for children’s clothing
  5. 16 CFR 1615.1(a) — Definition of children’s sleepwear
  6. 16 CFR part 1616 — Children’s sleepwear, sizes 7 through 14
  7. 16 CFR 1307.2 — Definition of child care article
  8. 16 CFR 1120.3(b) — Drawstrings in children’s upper outerwear
  9. 16 CFR 1501.3 — Small parts rule exemptions
  10. CPSC, Tracking Label FAQ
  11. CPSC, Rules requiring a General Certificate of Conformity
  12. CPSC, Product Registry FAQ v1.4 (updated Apr. 28, 2026)