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Questions · Which rules apply

Which CPSC tests does a children’s pillow need: lead, phthalates, flammability?

A children’s pillow needs a Children’s Product Certificate based on tests by a CPSC-accepted lab, mainly for lead: total lead in accessible parts such as foam, zippers and prints, and the lead paint limit for coatings. Phthalate tests apply only to toys and to pillows made mainly for children 3 and younger. No federal flammability standard covers bed pillows.

The rules that apply

  • Lead: no more than 100 ppm in any accessible part 15 U.S.C. 1278a. Paint, coatings and prints whose ink scrapes off meet the 90 ppm lead paint limit 16 CFR part 1303.
  • Phthalates: only toys and child care articles 16 CFR part 1307, like products that help children 3 and younger sleep 16 CFR 1307.2(b). Age is judged by a reasonable label, marketing, consumer perception and CPSC guidelines 15 U.S.C. 2057c(g)(2)(A). In our reading, a pillow sold for ages 3 and up is not mainly for 3 and younger and is usually outside; but age 3 is in both, and a 2008 letter reads it broadly CPSC, 2008. Toddler and play pillows are in.
  • A permanent tracking label on the pillow and, where practicable, its packaging 15 U.S.C. 2063(a)(5); hangtags and stickers do not count CPSC FAQ.
  • No federal flammability test for a bed pillow: mattress standards exclude pillows 16 CFR 1632.1(a) 16 CFR 1633.2(a).
  • A pillow marketed for babies falls under the infant support cushion standard 16 CFR part 1243; a loosely bead-filled one for babies under 1 is banned 16 CFR 1500.18(a)(16).

Component by component

ComponentLead contentPhthalates, if required
Cotton coverExempt if it carries nothing but dyes 16 CFR 1500.91(d)(7)No test, if not treated with anything that may contain phthalates CPSC phthalates FAQ
Polyester or spandex cover, linerSame textile exemption 16 CFR 1500.91(d)(7)No test only if unfinished, with no dye 16 CFR 1253.2; otherwise test it
Memory foamTest it, unless inaccessibleTest it, unless inaccessible 16 CFR 1199.1(i)
Zipper slider, pull and teethTest it, unless bare stainless steel 16 CFR 1500.91(e)No test for bare metal CPSC phthalates FAQ; test plastic or coatings, unless a plastic CPSC exempts 16 CFR 1308.2
Prints and printed labelsPaint limit if the ink scrapes off; otherwise total lead CPSC lead in paint FAQTest them

One zipper changes the list

A fabric cover shields the foam only if it stays closed, passes the use-and-abuse tests for the age group, and the pillow is at least 5 cm in every dimension 16 CFR 1500.87(i). If a child can open the cover, test the foam at an accepted lab CPSC lab list.

A cotton-covered foam bed pillow usually enters under HTS 9404.90.1030 HTSUS 9404.90, off CPSC’s eFiling list CPSC HTS list, Oct. 2026; its certificate is still eFiled 16 CFR 1110.13(a)(1).

How PortCert handles this

You can order the tests and write the certificate yourself. If you would rather not, send us your lab reports: we match each result to its rule and component, check the lab’s CPSC acceptance for each test and flag any gap, then write the CPC, the Registry import file and the broker sheet. $79 per product, 2 U.S. business days. Our free check tells you which tests to order first. We do not test products.

Get the free check Children’s Product Certificate

Last reviewed: October 29, 2026 · First published: October 14, 2026 · Not legal advice.

Sources read October 29, 2026

  1. 15 U.S.C. 1278a — Lead limits in children’s products
  2. 16 CFR part 1303 — Lead in paint and similar surface coatings
  3. CPSC, FAQ: Lead in Paint (textile screen-printing inks)
  4. 16 CFR part 1307 — Phthalates in children’s toys and child care articles
  5. 16 CFR 1307.2 — Definition of child care article
  6. 15 U.S.C. 2057c(g)(2)(A) — Phthalates: how the age a product is intended for is determined
  7. CPSC, FAQ: Phthalates (materials that need no test; mattresses for children 3 and younger)
  8. CPSC Office of the General Counsel, advisory opinion No. 321 on phthalates and children’s sleepwear (Nov. 25, 2008)
  9. 15 U.S.C. 2063 — Certificates, third-party testing, tracking labels
  10. CPSC, Tracking Label FAQ
  11. 16 CFR 1632.1(a) — Definition of mattress (pillows excluded)
  12. 16 CFR 1633.2(a) — Definition of mattress, open-flame standard (pillows excluded)
  13. 16 CFR part 1243 — Infant support cushions
  14. 16 CFR 1500.18(a)(16) — Banned infant cushions and pillows (loose granular fill, under one year)
  15. 16 CFR 1500.91(d)(7) — Lead content determination for textiles
  16. 16 CFR 1253.2 — Determinations for unfinished manufactured fibers
  17. 16 CFR 1199.1 — Phthalates: inaccessible component parts
  18. 16 CFR 1500.91(e) — Lead content determination for stainless steel and precious metals
  19. 16 CFR 1308.2 — Plastics that need no phthalate test (PP, PE, polystyrene, ABS, with listed additives)
  20. 16 CFR 1500.87 — Lead: inaccessible component parts (fabric-covered parts)
  21. CPSC, list of CPSC-accepted testing laboratories
  22. USITC, Harmonized Tariff Schedule, subheading 9404.90 (pillows)
  23. CPSC, Guidance and HTS List for eFiling, October 2026 (Excel, posted Sept. 30, 2026)
  24. 16 CFR 1110.13 — Certificate availability and eFiling