Flammable Fabrics Act (FFA) Guide For United States Importers

The Flammable Fabrics Act (FFA) regulates flammability in clothing, carpets, mattresses, and other products – either manufactured in or imported to the United States. In this guide, we explain how the FFA works and what you must do to ensure compliance.

Which products are covered by the Flammable Fabrics Act (FFA)?

As explained in this guide, the FFA covers a wide range of consumer products. Here are some examples:

• Clothing textiles
• Children’s sleepwear
• Upholstered furniture
• Mattresses
• Carpets and rugs

Keep in mind that different standards and flammability requirements apply depending on the product. This is further explained in this guide.

Clothing Textiles and Vinyl Plastic Film Products

16 CFR Part 1610 – Standard for the Flammability of Clothing Textiles – and 16 CFR Part 1611 – Standard for the Flammability of Vinyl Plastic Film – provide test methods to determine the degree of flammability of clothing textiles and vinyl plastic film products. The goal is to reduce the risk due to highly flammable fabrics for the end user.

Product Scope

Both 16 CFR Parts 1610 and 1611 are standards that provide methods for testing the flammability of clothing apparel materials such as textiles and vinyl plastic film products.

Clothing textiles

16 CFR Part 1610 covers clothing and clothing textiles, including the following:

• Garments
• Costumes

The standard does not cover the following product types:

a. Hats

b. Gloves shorter than 14 inches

c. Footwear (if it doesn’t have any amount of hosiery, or isn’t part of another item of clothing)

d. Interlining fabrics

It also exempts products made of Class I fabrics, which include:

a. Plain surface fabrics with a weight of 2.6 ounces per square yard

b. Fabrics consisting of fibers such as acrylic, modacrylic, nylon, olefin, polyester, and wool

Vinyl plastic film

16 CFR Part 1611 covers vinyl plastic film that fit the following descriptors:

a. Nonrigid and unsupported

b. Transparent, translucent, and opaque material

c. Plain, embossed, or molded

Examples of covered products include the following items:

• Knitted fabrics
• Undergarments

16 CFR Part 1610 – Standard for the Flammability of Clothing Textiles

16 CFR Part 1610 sets flammability and other requirements for clothing textile products.

Flammability Requirements

The standard establishes the flammability testing methods, performance requirements, and classification of textile clothing products.

Plain surface textile fabrics and raised surface textile fabrics are classified into three classes depending on their flammability during testing. Class 1 and 2 textiles may be used for clothing, while Class 3 textiles are considered too flammable for use.

	Plain surface textile fabrics	Raised surface textile fabrics
Class 1 Normal Flammability	Burn time: > 3.5 seconds	Burn time: > 7 seconds
Class 2 Intermediate flammability	Not applicable	Burn time: 4-7 seconds
Class 3 Rapid and intense burning	Burn time: < 3.5 seconds	Burn time: < 4 seconds

Other Requirements

The standard mandates that fabric that is not supposed to be dry cleaned or washed during normal use, should not be dry cleaned or washed during testing either if the product includes a label such as the following:

“Fabric may be dangerously flammable if dry cleaned or washed.”

16 CFR Part 1611 – Standard for the Flammability of Vinyl Plastic Film

16 CFR 1611 establishes the flammability testing methods and other requirements for garments or products that are made of non-rigid, unsupported vinyl plastic film, such as disposable diapers, raincoats, and socks.

Flammability Requirements

This standard requires that the vinyl plastic film should burn at a rate that does not exceed 1.2 inches per second. The rate should be an average of five lengthwise burn tests, plus the average of five crosswise burn tests.

Other Requirements

Textile fabrics and wearing apparel, that under normal usage circumstances would not be dry cleaned and washed, should not be dry cleaned or washed if it carries the statement:

“Fabric may be dangerously flammable if dry cleaned or washed.”

Children’s Sleepwear

Both 16 CFR Parts 1615 and 1616 set requirements for the flammability of children’s sleepwear.

While Part 1615 determines the flammability requirements of children’s sleepwear sized 0 through 6X, Part 1616 determines the flammability requirements of children’s sleepwear sized 7 through 14.

Product Scope

16 CFR Parts 1615 and 1616 cover the following types of children’s sleepwear:

• Nightgowns
• Pajamas
• Robes

Both Parts 1615 and 1616 do not cover the following items:

• Diapers and underwear
• Tight-fitting garments

Part 1615 also does not cover the following types of infant garments:

• One-piece < 64.8 cm in length
• Two-pieces: < 40 cm in length

16 CFR Part 1615 – Standard for the Flammability of Children’s Sleepwear: Sizes 0 Through 6X

16 CFR Part 1615 is a standard that provides test methods used to determine the flammability of children’s sleepwear sized 0 through 6X.

Flammability Requirements

The test procedure includes requirements and equipment such as the following:

• Test chamber
• Specimen holder
• Burner
• Gas supply system
• Rejection criteria

Also, the average char length of the five test specimens, each 25.4 cm (10 in) in length, should not be more than 17.8 cm (7.0 in) long.

Labeling Requirements

Hangtags on the garment and packages (if the garments are sold in such) are required to carry a label with the following statements:

For child’s safety, garment should fit snugly.

This garment is not flame resistant.

Loose-fitting garment is more likely to catch fire.

The garments and packages should also carry another label in front of the sizing label with the following information:

WEAR SNUG-FITTING

NOT FLAME RESISTANT

16 CFR Part 1616 – Standard for the Flammability of Children’s Sleepwear: Sizes 7 Through 14

16 CFR Part 1616 is a standard that provides test methods used to determine the flammability of children’s sleepwear sized 0 through 6X.

Flammability Requirements

The test procedure includes the following equipment:

• Test chamber
• Specimen holder
• Burner

The average char length of five specimens should not be more than 17.8 cm (7.0 in).

None of the five specimens should have a full-specimen burn char measuring between 24.9 cm (11.5 in) and 25.9 cm (10.2 in).

Labeling Requirements

16 CFR Part 1616’s requirements regarding flammability warnings on hangtags and sizing labels are the same as those stated in Part 1615.

Carpets and Rugs

16 CFR Parts 1630 and 1631 are standards for the flammability of carpets and rugs.

While Part 1630 determines the flammability requirements of relatively large carpets and rugs, Part 1631 determines the flammability requirements of small carpets and rugs.

Product Scope

Parts 1630 and 1631 both cover rugs and carpets, and also note that the terms “rug” and “carpet” are interchangeable.

Both standards cover finished floor coverings used for indoor spaces.

16 CFR Part 1630 – Standard for the Surface Flammability of Carpets and Rugs

16 CFR Part 1630 is a standard that provides test methods for determining the surface flammability of large carpets and rugs that have one dimension that exceeds 1.83 m (6 ft) and a surface area that exceeds 2.23 sq m (24 sq. ft).

“Carpet squares” with measurements less than what’s mentioned above are included if, when a set of such is assembled, the total size has one dimension greater than 6 ft and an area that exceeds 24 sq. ft.

Flammability Requirements

The standard requires eight 9 x 9-inch carpet specimens to each undergo a flame exposure test. These specimens pass the tests if the charred portion of the fabric does not come within 2.54 cm (1.0 in) of the edge of the hole of the frame used to secure the specimens.

Labeling Requirements

Part 1630 requires carpets or rugs – or the fibers within – that have been treated with fire retardant to carry a label with the letter “T” per the CPSC’s conditions.

16 CFR Part 1631 – Standard for the Surface Flammability of Small Carpets and Rugs

16 CFR Part 1631 is a standard that provides test methods for determining the flammability of small carpets and rugs that have dimensions that do not exceed 1.83 m (6 ft) and areas that do not exceed 2.23 sq. m (24 sq. ft).

Flammability Requirements

The standard requires the charred portion of the specimen (small carpet or rug) to not come within 2.54 cm (1.0 in) of the edge of the hole that is in the center of the frame that is used to hold the test specimen in place.

Labeling Requirements

16 CFR Part 1631 requires that regulated carpets and rugs that do not meet the requirements should include a legible and permanent label with this statement in bold:

“FLAMMABLE (FAILS U.S. DEPARTMENT OF COMMERCE STANDARD FF 2-70): SHOULD NOT BE USED NEAR SOURCES OF IGNITION”

Also, if a small carpet or rug has undergone special fire retardant treatment, it should be labeled with the letter “T”.

Mattresses

In the interest of a sleeping consumer’s safety, it should be as difficult as possible for mattresses to catch fire. 16 CFR Parts 1632 and 1633 are standards that provide test methods for determining how flammable mattresses, mattress pads, and mattress sets are.

Product Scope

16 CFR Parts 1632 covers different types of mattresses and mattress pads such as the following:

• Adult, youth, crib, and bunk bed mattresses
• Futons
• Flip chairs without arms or permanent backs
• Sleeper chairs
• Water beds
• Air mattresses

16 CFR Parts 1633 covers mattress sets.

16 CFR Part 1632 – Standard for the Flammability of Mattresses and Mattress Pads

16 CFR Part 1632 – Standard for the Flammability of Mattresses and Mattress Pads establishes flammability testing materials, equipment methods, and performance requirements for mattresses and pads when exposed to smoldering ignition sources such as lighted cigarettes and matches.

Flammability Requirements

The standard requires that the char length of individual cigarette test locations does not exceed 2 inches (5.1 cm) in any direction from the point nearest the cigarette.

Labeling Requirements

16 CFR Part 1632’s labeling requirements for mattresses and mattress pads are as follows:

a. Mattress pads that contain chemical fire retardant material should be prominently labeled with the letter “T”.

b. Pads that are treated with fire retardant should be labeled with precautionary instructions to protect the fire-retardant materials from damage

Labels of mattresses and pads should also disclose information like the month and year of manufacture and the location of the manufacturer.

16 CFR Part 1633 – Standard for the Flammability (Open Flame) of Mattress Sets

16 CFR Part 1633 – Standard for the Flammability (Open Flame) of Mattress Sets is a standard that applies to mattress sets, which should include mattresses without foundation.

The standard establishes flammability requirements and testing procedures for mattress sets to decrease incidents and injuries caused by mattress fires.

Flammability Requirements

16 CFR Part 1633 requires that two main test criteria be met for a specimen (mattress) to pass the 30-minute test:

a. The heat release’s peak rate should not be more than 200 kilowatts at any time

b. During the first 10 minutes of the test, the total release of heat should not be more than 15 megajoules (MJ)

Labeling Requirements

The standard specifies labeling requirements for mattress sets, which should include a legible label(s) containing the following information in English:

• Business information (name, company address of the manufacturer and importer)
• Date of manufacture (year and month)
• Model identification number
• A certification or test report proving the compliance of the mattress sets

The standard also requires to display one of the following labels, according to the circumstances:

“THIS MATTRESS IS INTENDED TO BE USED WITHOUT A FOUNDATION.”

“THIS MATTRESS IS INTENDED TO BE USED WITH FOUNDATION(S).”

“THIS MATTRESS IS INTENDED TO BE USED WITHOUT A FOUNDATION OR WITH FOUNDATION(S)”

Upholstered Furniture

Importers and manufacturers of upholstered furniture should make sure that their products are as non-flammable as possible, by ensuring that their products comply with the FFA and the California TB 117-2013.

Product Scope

Part 1640 covers products such as the following:

• Bedding products
• Foundation
• Upholstered furniture, including cushions or pillows

16 CFR Part 1640 – Standard for the Flammability of Upholstered Furniture

16 CFR Part 1640 – Standard for the Flammability of Upholstered Furniture is a standard that provides requirements for the flammability of upholstered furniture.

Flammability Requirements

The standard incorporates the testing requirements found in the California Technical Bulletin (TB) 117-2013, titled “Requirements, Test Procedure and Apparatus for Testing the Smolder Resistance of Materials Used in Upholstered Furniture”.

Labeling and Certification Requirements

Products covered by this standard are required to carry a permanent label that has the following statement:

“Complies with U.S. CPSC requirements for upholstered furniture flammability”

The label certifies that the product complies with TB 117-2013 testing requirements.

Further, 16 CFR Part 1640 states that products covered by TB 117-2013 should not be subject to the requirements in Section 14(a) of the CPSC where testing and certification is concerned. This means that a General Certificate of Conformity is not needed.

General Certificate of Conformity (GCC)

The General Certificate of Conformity (GCC) is a document demonstrating the safety and compliance of consumer products, excluding children’s products, drafted either by the importer or the manufacturer.

A GCC is necessary for products covered by the Flammable Fabric Act, excluding the following:

a. Upholstered furniture, for which the above-mentioned label is enough

b. Children’s sleepwear, for which a Children’s Product Certificate (CPC) must be drafted instead

Here is a list of information that should be displayed in the document:

• Product identity (model number, name)
• Safety standards for which the product is certified (ie. 16 CFR Part 1630)
• Identification and contact information of the importer or domestic manufacturer
• Date and place of production
• Testing company information (if any)

Flammable Fabrics Act Testing

Although the CPSC might not necessarily require lab testing for all the products covered by the FFA, the products are still required to conform to relevant standards.

As such, their conformity might only be confirmed via testing, unless the product is made with materials that are deemed “non-flammable”, such as plain surface fabrics with a weight of 2.6 ounces per square yard.

The importer’s or manufacturer’s GCC should reflect this fact if their products comply with the applicable standards, and include information about the testing company.

Testing methods

Testing companies make use of various kinds of test methods outlined in the FFA standards above to determine the flammability of clothing and apparel fabrics. Test methods include:

• Open flame test
• Cigarette test

Testing companies

FFA-related lab testing services are offered by several companies – both in the United States and in Asia. Here are some companies offering FFA testing services:

• QIMA
• Underwriters Laboratories
• SGS
• TÜV Rheinland