In the United States, sleeping bags are subject to various standards, labeling, and testing requirements. In this guide, we take a closer look at 16 CFR Part 303, ASTM F1955, Law Labels, California Proposition 65, and other compliance requirements relevant to sleeping bags.
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16 CFR Part 303 – Rules and Regulations Under the Textile Fiber Products Identification Act
16 CFR Part 303 sets labeling requirements for textile products, which, per the FTC guidance page, include sleeping bags.
The regulation generally requires importers and manufacturers of textile products to provide labeling information such as:
- Fiber content
- Company name or registered identification number
- Country of origin
For example, a sleeping bag that only contains lining and filling material, could have a label with the following fiber content information:
- Lining: 100% Cotton
- Filling: 100% Polyester
You can find more information on labels for products that contain linings, fillings, and similar components in 16 CFR Part 303.22.
The regulation also sets recordkeeping and guaranty requirements.
16 CFR Part 300 – Rules and Regulations Under the Wool Products Labeling Act of 1939
16 CFR Part 300 sets labeling requirements for wool products. It is relevant to sleeping bags as wool may be used as filling material for these products. The regulation generally mandates that importers and manufacturers provide information on their labels, such as:
- Fiber content (e.g. 100% wool)
- Maximum percentage of the total weight of the filling of the wool product
- Manufacturer name or registered identification number
- Country of the wool’s origin
The regulation also establishes guaranty and record maintenance requirements.
Uniform Law Label
More than half the states in the United States, such as California, require a Law Label for many products that contain filling materials. The Law Label is used to identify the materials used in the product. Several states also require the provision of a Uniform Registry Number (URN) on the label.
The International Association of Bedding and Furniture Labeling Officials (IABFLO) specifies on its website that sleeping bags (as well as other products containing filling material) sold in the United States need to have such labels attached to them.
The requirements vary among states. Here we provide an example concerning the California requirements. According to the California BHGS, you should affix a Type No. 7 label to your sleeping bag. This label should contain the following information:
- An “UNDER PENALTY …” statement
- An “ALL NEW MATERIAL” statement, and the materials used
- “Finished Size” information
- “Net Weight of Filling Material” information
- “REGISTRY NO.”
- A “Certification is made …” statement
- Other information (e.g. manufacturer name, “Made by” information)
Consumer Product Safety Improvement Act (CPSIA)
The CPSIA establishes regulatory requirements for all children’s products designed and manufactured for children aged 12 and younger, including sleeping bags intended for children.
The CPSIA generally requires children’s products to:
- Undergo testing by a third-party CPSC-accepted lab
- Comply with substance restrictions and other safety requirements (e.g. flammability)
- Be accompanied by a Children’s Product Certificate
- Bear a tracking label
Durable infant products, such as infant sleep products, must also comply with additional requirements.
Children’s Product Certificate
The CPSIA requires manufacturers and private labelers to provide a Children’s Product Certificate. The certificate should contain:
- Product name and description
- List of applied and required ASTM and CPSC standards
- Information about importer or domestic manufacturer
- Contact information of the holder of the test report
- Manufacture date and location
- Testing date and location
- Identification of third-party CPSC-accepted test company
Tracking label requirements
The CPSIA mandates that children’s products bear a tracking label, which should contain:
- Name of importer/private labeler or manufacturer
- Date and location of manufacture
- Product identification information (e.g. name, batch number)
- Manufacturer contact information (e.g. address, phone number)
Requirements for wearable sleeping bags
The CPSC considers baby sleeping bags to be “general wearing apparel” that are subject to the requirements of 16 CFR Part 1610, but only if the baby wears sleep clothes prior to being put in the sleeping bag.
However, if the baby wears nothing but a diaper before being put into the sleeping bag, then the CPSC considers the product to be sleepwear subject to the requirements of 16 CFR Part 1615.
16 CFR Part 1610 – Standard for the Flammability of Clothing Textiles
This standard sets flammability requirements for clothing textiles. It classifies covered products in three classes:
a. Class 1 – Tested fabrics exhibit “normal flammability”. Suitable for clothing
b. Class 2 – Tested fabrics exhibit “intermediate flammability”. Suitable for clothing
c. Class 3 – Tested fabrics exhibit “rapid and intense burning”. Not suitable for clothing
16 CFR Part 1615 – Standard for the Flammability of Children’s Sleepwear: Sizes 0 through 6X (FF3-71)
This standard sets flammability requirements for children’s sleepwear. It also requires covered products to contain care labels and other labeling information.
Requirements for infant sleep products
The CPSC specifies that an “infant sleep product” is meant to accommodate a sleeping infant aged up to 5 months. Thus, this could also include sleeping bags – even though the CPSC does not explicitly state that sleeping bags are considered infant sleep products.
16 CFR Part 1236 – Safety Standard for Infant Sleep Products incorporates ASTM F3118 by reference, thereby mandating that infant sleep products comply with the standard’s requirements. It also sets additional requirements. For example, products should comply with the requirements concerning Maximum Seat Back/Sleep Surface Angle set by 16 CFR Part 1236, instead of complying with 6.9 of ASTM F3118.
Requirements for durable infant products
Per the CPSC, “infant sleep products” are durable infant or toddler products, and thus are covered by the requirements set by 16 CFR Part 1130. Such products are required to be accompanied by a product registration card.
Durable infant or toddler products should also comply with the following additional labeling requirements:
- The manufacturer’s name and contact information (US address and phone number)
- Model name and number
ASTM standards
Compliance with ASTM standards incorporated by reference into regulations is mandatory (e.g. ASTM F3118 in 16 CFR Part 1236). However, even if standards are not incorporated, you should still use them in order to achieve product safety.
Here we list all the standards we could find that specifically cover sleeping bags. Note that more standards may exist.
ASTM F1955 – Standard Test Method for Flammability of Sleeping Bags
ASTM F1720 – Standard Test Method for Measuring Thermal Insulation of Sleeping Bags Using a Heated Manikin
ASTM F2568 – Standard Test Method for Measurement of Sleeping Bags
ASTM F1932/F1932M – Standard Test Method for Measuring Sleeping Bag Loft
ASTM F1853 – Standard Test Method for Measuring Sleeping Bag Packing Volume
19 CFR Part 134 – Country of Origin Marking
Consumer products are generally required to bear a country of origin marking.
For example, a sleeping bag bearing a “Made in Indonesia” label tells buyers that the product was made in Indonesia.
In another instance, a sleeping bag with a label stating “Assembled in Mexico from components of India and Vietnam” tells consumers that the components of the sleeping bag were from India and Vietnam, and subsequently assembled in Mexico.
California Proposition 65
California Proposition 65 restricts the use of dangerous substances in consumer products in the state, such as sleeping bags. Some materials used to make sleeping bags, such as nylon or polyester, may contain restricted substances, such as:
a. PFOA – used as water repellant
b. TCEP – used as flame retardant
Importers and manufacturers should test their sleeping bags to ensure the product does not contain restricted substances. If they are not sure whether their product complies with the substance restrictions, they should affix a warning label to their product.
The warning statement should have a warning symbol before the word “WARNING”, and read, for instance:
“WARNING: This product can expose you to chemicals including PFOA, which is known to the State of California to cause cancer. For more information, go to www.P65Warnings.ca.gov.”
Lab Testing
You should have your sleeping bags tested to prove product compliance against requirements such as flammability or substance restrictions. While some regulations such as CPSIA mandate product testing, for others testing is a practical necessity to ensure product safety. If your product passes testing, you receive a test report indicating product compliance.
| Regulation | Lab testing |
| CPSIA | The CPSIA sets product-specific requirements, which may include testing against substance restrictions, flammability, or mechanical risks.
For instance, you should test your wearable sleeping bag zippers to ensure they do not contain more than 0.01% lead. |
| ASTM Standards | Sleeping bag products should undergo testing according to relevant ASTM standards. This may include:
|
| California Proposition 65 | California Proposition 65 sets substance restrictions for consumer products such as sleeping bags, which may contain PFOA and TCEP, for example.
Sleeping bags should undergo testing to ensure that they do not contain restricted substances above the set limits |
Sleeping bag testing companies
Here we list some companies that can test sleeping bags and related products such as clothing textiles, children’s sleepwear, and infant sleep products:
- Vartest
- Intertek
- Bureau Veritas
- SGS
