Certification and Registration
16 CFR 1616 Flammability Standard for Children’s Sleepwear
Category:
CPC
What is the purpose of establishing flammability standards for children’s sleepwear?
To protect children from burns, these regulations require that children’s sleepwear be flame‑retardant and self‑extinguish if ignited by a candle, match, lighter, or similar flame. They cover sleepwear in sizes from 9 months through 14, and require either:
(1) passing specified flammability tests; or
(2) being "tight‑fitting" according to defined dimensions.
Applicable Standards
16 CFR 1616 Standard for the Flammability of Children’s Sleepwear (sizes 7–14).
What is children’s sleepwear?
Children’s sleepwear means garments of any size from 9 months to size 14, primarily intended for sleeping or sleep‑related activities – e.g., pajamas, nightgowns, robes, or loungewear.
To determine if a garment is sleepwear, consider:
1.Its nature and suitability for sleep or sleep‑related activities.
2.How it is promoted and sold.
3.Whether it is commonly used by children for sleep.
Underwear and diapers are not sleepwear. Garments sized 9 months or smaller for infants are exempt if:
(1) they are a single piece ≤25¾ inches long, or two pieces each ≤15¾ inches; and
(2) they bear a label indicating age in months. Even if exempt, they must still comply with 16 CFR §1610 (apparel textiles) and §1611 (vinyl plastic films).
How should sleepwear be tested for flammability?
The following is a general overview; for detailed equipment, procedures, and sampling, refer to the regulation or contact SATISFY.
Test Method :
Typically, five specimens (3.5" × 10") are cut from fabric, seams, or trims. Each is mounted vertically in a test cabinet. A gas flame is applied to the bottom edge for 3 seconds. Char length is measured for each.
Test Samples and Judgment :
Testing covers three categories – fabric, prototype seams/trims, and production garment seams. Fabrics (or garments) must be tested as‑produced (or after one wash) and after 50 washes. Based on results, items are accepted, rejected, or require additional sampling. Generally, the average char length of five samples must not exceed 7.0 inches, and individual char lengths of 10 inches or longer must not exceed permitted counts.
Fabric: Finished fabrics are grouped into Fabric Production Units (FPUs) – up to 5,000 linear yards. Different colors/prints may be included if burning characteristics are similar. Test five specimens from each end of each FPU. An FPU is accepted or rejected per the sampling plan. If 15 consecutive FPUs pass, the yardage limit may increase. Rejected FPUs require a third test with five samples from the middle of the next FPU.
Prototype garments: Before mass production, test prototypes of each design – particularly seam types and trims. Most bindings or cuffs need not be tested. Test three samples of the longest seam (five inches each) and of each distinct seam type (10 inches or longer), plus three samples of each trim. Acceptance/rejection follows the prototype sampling plan.
Production garments: Finished garments are grouped into Garment Production Units (GPUs) – up to 500 dozen per GPU, with different trims/fasteners but same fabric, thread, and seam construction (size, color, print may vary). Test three samples of the longest seam types from randomly selected garments, with five specimens per sample. GPU is accepted or rejected per the production sampling plan.
What if the pajamas fail the flammability test?
Rejected units may not be retested, used, or sold as children’s sleepwear. They may be destroyed, exported (with CPSC approval), or reworked. Reworked units must be retested per FPU/GPU procedures. All must meet flammability requirements before being marketed.
How do you make a tight-fitting pajama?
Tight‑fitting sleepwear must:
(1) Not exceed maximum dimensions for chest, waist, seat, upper arm, thigh, wrist, or ankle as specified.
(2) Have no fabric trim (lace, ribbons) extending more than ¼ inch from attachment.
(3) Have sleeves tapering gradually from shoulder to end.
(4) Have pant legs tapering gradually from thigh to hem.
(5) If one‑piece, taper from chest to waist and from seat to waist.
(6) If two‑piece:
(a) taper from chest to hem;
(b) the lowest fastener within 6 inches of bottom edge;
(c) lower garment taper from seat to top.
(7) Have a permanent label indicating size.
(8) Have a label warning that the garment is not flame‑retardant and should be worn tightly.
(9) Comply with all apparel textile and vinyl plastic film flammability requirements.
Marketing responsibilities of retailers, distributors, and wholesalers
Those selling children’s sleepwear (including infant sizes 9 months and under, and tight‑fitting garments) must:
(1) Not ignore claims of non‑compliance; do not advertise or sell as sleepwear any garment not intended or suitable for sleep.
(2) Display or advertise fabrics/apparel covered by the sleepwear standard separately from similar non‑sleepwear items.
(3) Use signage or catalog/web descriptions to distinguish sleepwear from non‑sleepwear.
(4) Avoid advertising or promoting non‑compliant items in a way that leads consumers to regard them as sleepwear.
Labeling and record‑keeping requirements
(1) Each garment must have a permanent care label to protect flame‑retardant properties.
(2) A permanent label with unit identifier (numbers, letters, dates) to enable traceability for recalls.
(3) Manufacturers and importers must maintain required written records.
Other requirements
FTC labeling laws also apply. Although functional attachments (buttons, zipper pulls) are not subject to small‑parts regulations, SATISFY recommends voluntary testing for garments size 2 and under to prevent choking hazards (see 16 CFR §§1500.50‑1500.52 and 16 CFR Part 1501).
For more information, please contact SATIFY customer service. SATISFY offers one‑stop children’s sleepwear testing – including preliminary assessments, documentation preparation and submission, end‑to‑end monitoring of testing and certification, compliance labelling guidance, and post‑testing follow‑up.
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