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Last reviewed: September 2026 · Copy link

Children’s clothing flammability: 16 CFR Part 1610

16 CFR Part 1610 is the General Wearing Apparel flammability standard under the Flammable Fabrics Act: it classifies fabric burn speed and bans dangerously rapid-burning clothing. Children’s clothing sellers encounter it on nearly every garment CPC, alongside lead and tracking label rules. Testing measures how quickly a fabric sample burns; classes 1 (normal) pass, class 2 (intermediate) and class 3 (excessive) cannot be sold as apparel.

Which garments need 1610 testing

  • Most adult and children’s wearing apparel falls under 1610 unless another flammability standard covers them (children’s sleepwear has its own stricter rules under 16 CFR Parts 1615/1616).
  • Certain fabrics are exempt from testing: plain-surface fabrics above specific weights (like most denim and fleece over 2.6 oz/yd²) and specific trim items, per the standard’s exemption list.
  • Surface-fired embellishments, nap fabrics (velvet, corduroy), and sheer fabrics typically do require testing.

Sleepwear is a different, stricter world

Children’s sleepwear (sizes 9 months to 14) is governed by 16 CFR Parts 1615/1616 with much tighter flammability requirements, and garments must either pass flame testing or be a snug-fitting design meeting specific dimensions. If your product is sleepwear or could be marketed as sleepwear, treat it as its own compliance project and say so on the CPC.

Questions people ask

Do I need flammability testing for cotton t-shirts?

Plain-surface fabrics over the exempt weight threshold (such as standard cotton jersey) are exempt from 1610 testing, which is why basic tees rarely need burn tests. Document the exemption basis, and confirm with your lab.

What is class 3 fabric?

Class 3 is the fastest-burning classification and cannot be used in apparel. Class 2 is intermediate-burning, permitted for some uses with restrictions.

Does the CPC cite 1610 for every garment?

If the garment is a children’s product covered by 1610, yes: the CPC cites it along with lead and tracking label rules. The generator includes 1610 in the clothing preset.

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