The purpose of this standard is to promulgate a minimum standard of flammability for vinyl plastic film.
The requirements are codified at 16 C.F.R. part 1611.
For more information on the Flammable Fabrics Act (FFA), visit our FFA business guidance page.
The material covered under 16 C.F.R. part 1611 is nonrigid, unsupported, vinyl plastic film, including transparent, translucent, and opaque material, whether plain, embossed, molded, or otherwise surface treated.
Plastic-coated fabrics may be tested to either 16 C.F.R. part 1610 or part 1611, depending on how the layer of plastic film is adhered to the fabric. A coated fabric means a flexible material composed of a fabric and any adherent polymeric material applied to one or both surfaces.
In the case of multi-layer fabric with an outer layer of plastic film or plastic-coated fabric, if the outer layer separates readily from the other layers, the outer layer of plastic film or plastic-coated fabric shall be tested under 16 C.F.R. part 1611. If the outer layer adheres to one or more of the other layers, the multi-layered fabric may be tested to either 16 C.F.R. parts 1610 or 1611. See 16 C.F.R. §1610.34(b) for additional information.
Adult wearing apparel made from vinyl plastic film is 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 adult wearing apparel made from vinyl plastic film, must certify, in a written GCC, based on testing or a reasonable testing program, that the products comply with 16 C.F.R. part 1611.
Adult wearing apparel made from vinyl plastic film does not need to be tested at a third party, CPSC-accepted lab.
There are general requirements for products primarily designed or intended for children 12 years of age or younger:
- 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.
- 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. 16 C.F.R. § 1500.87 addresses determination of accessibility for the purposes of the total lead content rule.
- Phthalates: Children’s toys and child care articles as defined per 16 C.F.R. § 1307.2 must not contain greater than 0.1 percent (1000 ppm) of any regulated phthalate in any accessible component part. 16 C.F.R. § 1307.3 lists the regulated phthalates, and 16 C.F.R. part 1199 addresses determination of accessibility for the purposes of the phthalate rule.
- Third-party testing: Children’s products must be tested for compliance to applicable safety rules by a third-party, CPSC-accepted laboratory.
- Certification: Domestic manufacturers or importers of children’s products must generate a Children’s Product Certificate (CPC) certifying compliance to 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).
Apparel may be subject to additional regulatory requirements by the Federal Trade Commission (FTC) and, for imported goods, by U.S. Customs and Border Protection (CBP).
A few helpful documents discussing these requirements can be found at:
- FTC: Threading Your Way Through the Labeling Requirements Under the Textile and Wool Acts (Registered Identification Numbers)
- FTC: Clothes Captioning – Complying with the Care Labeling Rule
- CBP: What Every Member of the Trade Community Should Know About Textile & Apparel Rules of Origin
- CBP: Basic Importing and Exporting
Please contact those agencies with any questions you may have on their requirements.