On December 22, 2011, the U.S. Consumer Product Safety Commission (CPSC) Office of Compliance and Field Operations issued a letter that they would deem loungewear as children’s sleepwear, requiring it to meet the stringent children’s sleepwear flammability standard requirements per 16 CFR part 1615 and 1616 under the Flammable Fabrics Act.  This memo reiterated the CPSC policy on loungewear from 1996, but also highlighted additional requirements that loungewear and sleepwear must now meet due to the enactment of the Consumer Product Safety Improvement Act of 2008 (CPSIA).  Some of these requirements include third-party testing, phthalate content, lead content, lead in surface coatings and tracking labels.

The letter also emphasized that the requirements apply not only to brick-and-mortar retailers, but also to online sales.

A copy of the letter can be reviewed at: https://www.cpsc.gov/businfo/sleepwearpolicy.pdf.

The Challenge:
Children’s sleepwear flammability standards 16 CFR 1615 and 1616 are more stringent than the general wearing apparel flammability standard. Children’s sleepwear requires testing not only at final garment stage, but also in the fabric and prototype stages.

CPSC regulations define the term "children’s sleepwear" to include any product of wearing apparel (in sizes 0 – 14), such as nightgowns and pajamas, or similar or related items, such as robes, intended to be worn primarily for sleeping or activities related to sleeping, except:
(1)  diapers and underwear;
(2)  "infant garments," sized for a child nine months of age or younger; and
(3)  "tight-fitting garments" that meet specific maximum dimensions.

Are you prepared to design and manufacture children’s sleepwear that complies with all applicable requirements?

The Solution:
Through our extensive global network of laboratories and offices, Intertek offers a variety of services available to help you overcome the challenges related to complying with the children’s sleepwear flammability standard and other CPSIA requirements. In addition to keeping you ｕｐｄａｔｅd on any new developments, Intertek provides regulatory and strategic consulting, testing and implementation programs for compliance to the new regulations, enabling you to meet your business objectives.