Do kids’ pajamas need a new flammability test for every production lot?
Yes, for flame-resistant children’s sleepwear. Parts 1615 and 1616 require prototype tests of seams and trim before production, then a test of each fabric production unit (up to 5,000 yards) and each garment production unit (up to 500 dozen garments). A failing garment unit cannot be sold as sleepwear unless reworked and retested. Tight-fitting and infant garments follow other rules.
What is tested, and how often
| Stage | What the standard requires |
|---|---|
| Fabric | Each fabric production unit, up to 5,000 linear yards of finished fabric 16 CFR 1615.1(k): one sample of five specimens from each end, judged on average and individual char lengths 16 CFR 1615.4(c) 16 CFR 1615.3 |
| Prototype | Before production, three samples (15 specimens) of the longest seam, each other seam of 10 in or more, and each trim 16 CFR 1615.4(d)(2) |
| Production | Each garment production unit, up to 500 dozen finished garments 16 CFR 1615.1(l): three samples (15 specimens) cut from the longest seam of garments picked at random 16 CFR 1615.4(d)(3) |
Tests are run as produced (or after one wash) and after 50 washes; garments from fabric that passed after washing skip the washes 16 CFR 1615.4(b)(5), (g)(4). Sizes 7 to 14 follow the same scheme under part 1616 16 CFR 1616.2(i) 16 CFR 1616.2(j) 16 CFR part 1616.
What lets one test cover more
- Different colors or different print patterns of the same fabric, not both, can share one unit if earlier tests of at least three samples of each show char lengths that are not significantly different CPSC FAQ: what is sleepwear.
- Garments that differ only in size, trim and findings can share one garment unit; different colors or print patterns can too, under the condition above 16 CFR 1615.4(b)(2)–(3).
- After 15 fabric units in a row pass, a fabric unit may grow to 10,000 yards, until a unit fails 16 CFR 1615.4(c)(2).
Records, labels and your certificate
The manufacturer or importer that first markets these garments keeps records linking each unit to its sampling plan and results (each specimen’s char length, who tested, when), failing units and sales by unit or style, for 3 years (prototype records for as long as they are relied on, plus 3 years) 16 CFR 1615.31(e). Each garment carries a permanent label with its unit number, which can also serve as the batch number on the tracking label CPSC FAQ: what is sleepwear.
Your CPC still rests on tests by a CPSC-accepted lab CPSC FAQ: what is sleepwear, and children’s products need periodic third-party testing at least once a year, every two years with a production testing plan, or every three years with ongoing testing at an ISO/IEC 17025-accredited lab 16 CFR 1107.21. So ask the factory for the unit numbers in your shipment and their test records.
You can gather the unit records and order the lab tests yourself. If you would rather not, send us the style, the lab reports and the unit numbers in your shipment: we check that the reports cover those units and that the lab is CPSC-accepted for the tests, then write the CPC, the Registry import file and the broker sheet. $79 per certificate, 2 U.S. business days. We do not test garments.
Last reviewed: November 2, 2026 · First published: November 2, 2026 · Not legal advice.
Sources read November 2, 2026
- 16 CFR 1615.1(k) — Fabric production unit (up to 5,000 linear yards)
- 16 CFR 1615.1(l) — Garment production unit (up to 500 dozen)
- 16 CFR 1615.4 — Children’s sleepwear: test procedure (including laundering)
- 16 CFR 1615.3 — Children’s sleepwear: test criteria (char length)
- 16 CFR 1616.2(i) — Fabric production unit, sizes 7 through 14 (up to 5,000 linear yards)
- 16 CFR 1616.2(j) — Garment production unit, sizes 7 through 14 (up to 500 dozen)
- 16 CFR part 1616 — Children’s sleepwear, sizes 7 through 14
- CPSC, FAQ: Children’s Sleepwear
- 16 CFR 1615.31 — Children’s sleepwear: labeling, recordkeeping, guaranties
- 16 CFR 1107.21 — Periodic testing