Which rules apply to burp cloths
- Burp cloths are child care articles: lead and phthalate testing on the fabric, waterproof layers, and printed artwork for products used with children under 3.
- CPSIA section 101 total lead content in accessible substrate materials.
- 16 CFR part 1303 lead in paint and surface coatings where painted or coated.
- CPSIA section 103 tracking labels: manufacturer, location, and date of manufacture on product and packaging.
The testing and certification path
Testing covers lead in prints and dyes, phthalates in plasticized waterproof layers, and substrate screening on every fabric layer. Multi-layer constructions test each layer type.
Book testing at a laboratory that is CPSC-accepted for each rule, issue the CPC in your own name citing the rules your report supports, and keep the certificate with its test report for at least five years. Marketplaces ask for the pair, not the certificate alone.
Questions people ask
Do plain cotton burp cloths need testing?
Undyed cotton is low risk, but most burp cloths have prints or waterproof layers — those components are tested. Get the lab’s scope in writing.
Are they toys?
No: burp cloths are child care articles for children under 3. The phthalate limits apply to all accessible materials.
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