The purpose of the standards is to reduce deaths and injuries associated with mattress fires. 16 C.F.R. part 1632 addresses smoldering ignition and prescribes a test to determine the ignition resistance of a mattress or a mattress pad when exposed to a lighted cigarette. 16 C.F.R. part 1633 addresses flammability when exposed to an open flame and prescribes a test to determine the size of the fire generated by a mattress and/or mattress set during a 30-minute test.
There are two federal mattress flammability standards:
- Standard for the Flammability (Smoldering) of Mattresses and Mattress Pads codified at 16 C.F.R. part 1632
- Standard for the Flammability (Open Flame) of Mattress Sets codified at 16 C.F.R. part 1633
For more information on the Flammable Fabrics Act (FFA), visit our FFA business guidance page.
Mattress is defined at 16 C.F.R. §§ 1632.1(a) and 1633.2(a) as a resilient material or combination of materials enclosed by a ticking (used alone or in combination with other products) intended or promoted for sleeping upon.
Examples of mattresses include, but are not limited to, adult mattresses, youth mattresses, crib mattresses, portable crib mattresses, bunk bed mattresses, futons, flip chairs without a permanent back or arms, sleeper chairs, and water beds or air mattresses if they contain upholstery material between the ticking and the mattress core. Mattresses used in or as part of upholstered furniture are also include, such as convertible sofa bed mattresses, corner group mattresses, day bed mattresses, roll-away bed mattresses, high risers, and trundle bed mattresses.
The term “mattress” excludes mattress pads, mattress toppers, sleeping bags, pillows, liquid and gaseous filled ticking, such as water beds and air mattresses that contain no upholstery material between the ticking and the mattress core, upholstered furniture which does not contain a mattress, and juvenile product pads such as car bed pads, carriage pads, basket pads, infant carrier and lounge pads, dressing table pads, stroller pads, crib bumpers, and playpen pads.
Mattresses are subject to both 16 C.F.R. parts 1632 and 1633.
Mattress pad is defined at 16 C.F.R. § 1632.1(b) as a thin, flat mat or cushion, and/or ticking filled with resilient material for use on top of a mattress. The definition includes, but is not limited to, absorbent mattress pads, flat decubitus pads, and convoluted foam pads which are totally enclosed in ticking. Foam pads are specifically identified as being excluded from the scope of the standard.
Mattress pads are subject to the requirements of 16 C.F.R. part 1632.
Mattress set is defined at 16 C.F.R. § 1633.2(c) as either a mattress and a foundation labeled by the manufacturer for sale as a set or a mattress labeled by the manufacturer for sale without any foundation.
A foundation, as defined at 16 C.F.R. § 1633.2(b), means a ticking covered structure used to support a mattress or sleep surface. The structure may include constructed frames, foam, box springs, or other materials, used alone or in combination.
Products subject to 16 C.F.R. part 1632 must not create a char length more than 2 inches (5.1 cm) in any direction from the nearest point of the cigarette after testing. For details on the test method, see 16 C.F.R. § 1632.4 for mattresses and 16 C.F.R. § 1632.5 for mattress pads.
Each mattress or mattress pad must be permanently labeled with the month and year of manufacture and the location of manufacturer (the individual plant or factory at which the products are produced or assembled).
Mattress pads treated with a chemical flame retardant must be labeled prominently with the letter “T” and instructions on how to protect the pads from agents or treatments that can cause deterioration of their flame resistance. Products intended for one time use, as described at 16 C.F.R. § 1632.5(b)(1)(i), are not required to meet the labeling requirements at 16 C.F.R. § 1632.5(b)(3)(iii).
Specifics on the labeling requirement can be found at 16 C.F.R. § 1632.31(b).
Manufacturers and importers shall maintain the following records:
- Manufacturing specifications for each prototype;
- Certified test results, including the prototype identification number, date of test, test room conditions, results of each cigarette tested, name and signature of the tester, and ticking classification, if known;
- Well identified photographs of each surface tested (with sheeting removed) clearly showing each cigarette burn location;
- Records establishing that any substituted core or interior materials do not influence the ignition resistance of the prototype;
- The test results and details of all ticking classifications (or a certification from a ticking supplier) including the classification (A, B, or C); and
- Certified test results, photographs, and details of all tape edge substitution tests.
Per 16 C.F.R. § 1632.31(c)(12), the records shall be maintained for as long as the prototype is in production, the ticking is being used on the mattress or mattress pad prototype, and/or the tape edge material is being used on the mattress or mattress prototype, and then for an additional 3 years thereafter.
Specifics on the recordkeeping requirements can be found at 16 C.F.R. § 1632.31(c).
For more information, view the following resources:
Products subject to 16 C.F.R. part 1633 shall comply with both of the following criteria as stated at 16 C.F.R. § 1633.3(b):
- The peak rate of heat release shall not exceed 200 kilowatts (kW) at any time within the 30 minute test; and
- The total heat release shall not exceed 15 megajoules (MJ) for the first 10 minutes of the test.
For details on the test method, see 16 C.F.R. § 1633.7.
Each mattress set shall bear a permanent, conspicuous, and legible label containing the following information in English:
- Name of the manufacturer, or for imported mattress sets, the name of the foreign manufacturer and importer;
- For mattress sets produced in the US, the complete physical address of the manufacturer, and for imported mattress sets, the complete address of the foreign manufacturer, including country, and complete physical address of the importer or the US location where the required records are maintained if different from the importer;
- Month and year of manufacture;
- Model identification;
- Prototype identification number for the mattress set;
- A certification that the mattress complies with this standard; and
- A statement identifying whether the manufacturer intends the mattress to be sold alone or with a foundation.
Examples of the following labels can be found at the corresponding sections below:
- Labels for Domestic Mattress with Foundation (Figure 12 to 16 CFR part 1633)
- Labels for Imported Mattress with Foundation (Figure 13 to 16 CFR part 1633)
- Label for Domestic Mattress Alone and with Foundation and Label for Imported Mattress Alone with Foundation (Figures 14 and 15 to 16 CFR part 1633)
- Label for Domestic Mattress Only and Label for Imported Mattress Only (Figures 16 and 17 to 16 CFR part 1633)
Specifics on the labeling requirement can be found at 16 C.F.R. § 1633.12.
Prototype, as defined at 16 C.F.R. § 1633.2(l), means a specific design of mattress set that serves as a model for production units intended to be introduced into commerce and is the same with respect to materials, components, design and methods of assembly. A mattress intended for sale with a foundation(s) shall be considered a separate and distinct prototype from a mattress intended for sale without a foundation.
Manufacturers and importers shall maintain the following types of records:
- Test and manufacturing records
- Prototype records
- Pooling confirmation test records
- Quality assurance records
Required records must be maintained by the manufacturer or domestic importer for as long as mattress sets based on the prototype are being produced, and 3 years thereafter. For additional information on the specific types of records listed above see 16 C.F.R. § 1633.11.
For more information about 16 C.F.R. part 1633, view the following resources:
- Presentation: CPSC and the Mattress Industry - The Latest from the CPSC, March 2018
- Laboratory Test Manual for 16 C.F.R. Part 1633: Standard for the Flammability (Open Flame) of Mattress Sets, January 2011
- Presentation on Retailer Responsibilities and the Standard for the Flammability (Open-Flame) of Mattress Sets; July 17, 2007, Bethesda, MD
- Test and Recordkeeping Forms
- CPSC Small Business Office Webinar Series: Mattresses
- Questions and Answers: Standard for the Flammability (Open Flame) of Mattress Sets
Mattress sets that are regulated as medical devices by the Food and Drug Administration (“FDA”) do not need to comply with CPSC flammability requirements. This is a very narrow exemption that applies only if the mattress set is a medical device registered with the FDA. Simply making medical claims about a mattress set being a medical device does not take it out of the scope of 16 C.F.R. part 1632 and/or 16 C.F.R. part 1633. For questions about FDA requirements, contact the FDA.
The definition of “upholstered furniture” does not include mattresses at 16 C.F.R. § 1640.3(e)(3)(i). Mattresses are subject to 16 C.F.R. parts 1632 and 1633. If the mattress portion of the futon and/or sofa bed is detachable, the detached mattress is likely only subject to the flammability standards in 16 C.F.R. parts 1632 and 1633. The rest of the futon and/or sofa bed after the mattress is detached is likely subject to 16 C.F.R. part 1640. If the mattress portion of the futon and/or sofa bed is permanently attached to the rest of the product, the product as a whole is likely subject to 16 C.F.R. part 1640.
For more information about upholstered furniture flammability requirements, visit our FAQ page here.
General-use (non-children’s) mattresses, mattress pads, and mattress sets are required to have a General Certificate of Conformity, also known as a GCC. Manufacturers and importers of general-use products for which consumer product safety rules apply, such as general-use mattresses, mattress pads, and mattress sets, must certify, in a written GCC, based on testing or a reasonable testing program, that the products comply with 16 C.F.R. parts 1632 and/or 1633, as applicable.
Crib mattresses are also subject to 16 C.F.R. part 1241 and 16 C.F.R. part 1130. For more information, visit our crib mattress business guidance page.
There are general requirements for child care articles, defined at 16 C.F.R. § 1307.2, and children’s product that may apply:
- Lead in paint and similar surface coatings: Children’s products must not bear paint and/or similar surface coatings that contain more than 0.009 percent (90 ppm) lead.
- Examples include painted component parts (e.g., buttons, zippers, snaps), printing processes that use a liquid or semi-liquid surface coating that hardens (e.g., screen printing)
- Total lead content: Children’s products must not contain greater than 100 ppm (0.01 percent) of total lead content in any accessible component part.
- Examples include component parts (e.g., buttons, zippers, snaps), heat transfer vinyl, metallic threads/fibers
- The Commission determined that textiles (excluding those that contain treatments or applications that do not consist entirely of dyes) are not required to be tested for total lead content. More information is available on our total lead content business guidance page.
- Phthalates: Children’s toys and child care articles must not contain greater than 0.1 percent (1000 ppm) of any regulated phthalate in any accessible component part.
- Examples include plasticized component parts, certain screen-printing inks
- Third-party testing: Children’s products must be tested for compliance to applicable safety rules by a third-party, CPSC-accepted laboratory.
- Children’s products in continuous manufacture are also subject to periodic testing requirement.
- Certification: Domestic manufacturers or importers of children’s products must generate a Children’s Product Certificate (CPC) certifying compliance with the applicable safety rules and ensures that a CPC accompanies the distribution of the product.
- Tracking label: Children’s products must bear distinguishing, permanent marks on the product and any packaging that allow consumers to ascertain the identity of the manufacturer or private labeler, date and place of manufacture, detailed information on the manufacturing process (i.e., batch or run number), and the specific source of the product (e.g., address of the specific manufacturing plant).
CPSC has an e-mail list that provides periodic updates for mattresses, mattress pads, and mattress sets. You can subscribe for the Mattress Information Email List here.
To stay up to date on the status of rulemaking and Commission activities, you can also subscribe to CPSC’s Business Education Monthly Email Newsletter (check the box "Business Education").