Children's clothing (not sleepwear)
CPSC requirements for this product type. Group: Apparel.
Certificate and rules
As a children's product (the usual case)
- Certificate
- Children's Product Certificate (CPC)
- Testing by a CPSC-accepted lab
- Required for the rules marked below
- Rules that likely apply
- 16 CFR part 1610: Wearing apparel Third-party testing
- 15 U.S.C. 1278a: Total lead content Third-party testing
Conditional rules
These rules apply only when the condition fits your product.
- If product has paint, ink, or a similar surface coating: 16 CFR part 1303
- If has vinyl plastic film parts (e.g., rainwear): 16 CFR part 1611
- If contains or is sold with button cell or coin batteries (toys meeting the 16 CFR 1250 battery rules are exempt from part 1263): 15 U.S.C. 2056e; 16 CFR 1263.3; 16 CFR 1263.4
Notes
Flammability (16 CFR 1610) plus lead content. Untreated textiles are determined not to exceed lead limits (16 CFR 1500.91(d)(7)), so testing targets buttons, snaps, zippers, rhinestones, and coatings. Fabrics in 16 CFR 1610.1(d) are exempt from flammability testing, but children's apparel does not get CPSC's certificate enforcement discretion. Phthalates generally do not apply (not a toy or child care article). Drawstrings on children's upper outerwear (sizes 2T-16) must meet ASTM F1816-97 (16 CFR 1120.3(b), a substantial product hazard rule that is not on CPSC's certificate lists). CPSC's Sept 2026 eFiling disclaim guidance excludes "drawstrings" from the 15(j) products that may file a disclaim, so confirm how drawstring compliance is handled at eFiling. HTS list = every CPSC-flagged Wearing Apparel line except sleepwear lines and adult scarves (matched by USITC text).
Other requirements
- Tracking label (CPSIA section 103) on product and packaging
- Drawstring requirements for children's upper outerwear (16 CFR 1120.3(b))
HTS subheadings
Subheadings commonly used for this product type (your broker confirms the full classification).
| 6-digit subheading | CPSC flags |
|---|---|
| 6101.20 | 0 flagged as certificate data required (CP2), 1 flagged as may be needed (CP1) |
| 6101.30 | 0 flagged as certificate data required (CP2), 1 flagged as may be needed (CP1) |
| 6102.20 | 0 flagged as certificate data required (CP2), 1 flagged as may be needed (CP1) |
| 6102.30 | 0 flagged as certificate data required (CP2), 1 flagged as may be needed (CP1) |
| 6103.42 | 1 flagged as certificate data required (CP2), 4 flagged as may be needed (CP1) |
| 6103.43 | 0 flagged as certificate data required (CP2), 5 flagged as may be needed (CP1) |
| 6104.41 | 0 flagged as certificate data required (CP2), 1 flagged as may be needed (CP1) |
| 6104.42 | 0 flagged as certificate data required (CP2), 1 flagged as may be needed (CP1) |
| 6104.43 | 0 flagged as certificate data required (CP2), 2 flagged as may be needed (CP1) |
| 6104.44 | 0 flagged as certificate data required (CP2), 1 flagged as may be needed (CP1) |
| 6104.52 | 0 flagged as certificate data required (CP2), 1 flagged as may be needed (CP1) |
| 6104.53 | 0 flagged as certificate data required (CP2), 1 flagged as may be needed (CP1) |
| 6104.59 | 0 flagged as certificate data required (CP2), 1 flagged as may be needed (CP1) |
| 6104.62 | 0 flagged as certificate data required (CP2), 7 flagged as may be needed (CP1) |
| 6104.63 | 0 flagged as certificate data required (CP2), 7 flagged as may be needed (CP1) |
| 6105.10 | 0 flagged as certificate data required (CP2), 2 flagged as may be needed (CP1) |
| 6105.20 | 0 flagged as certificate data required (CP2), 2 flagged as may be needed (CP1) |
| 6106.10 | 0 flagged as certificate data required (CP2), 2 flagged as may be needed (CP1) |
| 6106.20 | 0 flagged as certificate data required (CP2), 3 flagged as may be needed (CP1) |
| 6106.90 | 0 flagged as certificate data required (CP2), 1 flagged as may be needed (CP1) |
| 6107.91 | 0 flagged as certificate data required (CP2), 2 flagged as may be needed (CP1) |
| 6107.99 | 0 flagged as certificate data required (CP2), 3 flagged as may be needed (CP1) |
| 6108.11 | 0 flagged as certificate data required (CP2), 1 flagged as may be needed (CP1) |
| 6108.91 | 0 flagged as certificate data required (CP2), 2 flagged as may be needed (CP1) |
| 6108.92 | 0 flagged as certificate data required (CP2), 2 flagged as may be needed (CP1) |
| 6108.99 | 0 flagged as certificate data required (CP2), 1 flagged as may be needed (CP1) |
| 6109.10 | 0 flagged as certificate data required (CP2), 4 flagged as may be needed (CP1) |
| 6109.90 | 0 flagged as certificate data required (CP2), 4 flagged as may be needed (CP1) |
| 6110.11 | 0 flagged as certificate data required (CP2), 2 flagged as may be needed (CP1) |
| 6110.12 | 0 flagged as certificate data required (CP2), 2 flagged as may be needed (CP1) |
| 6110.19 | 0 flagged as certificate data required (CP2), 2 flagged as may be needed (CP1) |
| 6110.20 | 0 flagged as certificate data required (CP2), 5 flagged as may be needed (CP1) |
| 6110.30 | 0 flagged as certificate data required (CP2), 4 flagged as may be needed (CP1) |
| 6111.20 | 10 flagged as certificate data required (CP2), 0 flagged as may be needed (CP1) |
| 6111.30 | 10 flagged as certificate data required (CP2), 0 flagged as may be needed (CP1) |
| 6111.90 | 13 flagged as certificate data required (CP2), 0 flagged as may be needed (CP1) |
| 6112.31 | 0 flagged as certificate data required (CP2), 1 flagged as may be needed (CP1) |
| 6112.41 | 0 flagged as certificate data required (CP2), 2 flagged as may be needed (CP1) |
| 6114.20 | 1 flagged as certificate data required (CP2), 2 flagged as may be needed (CP1) |
| 6114.30 | 0 flagged as certificate data required (CP2), 1 flagged as may be needed (CP1) |
| 6201.20 | 0 flagged as certificate data required (CP2), 3 flagged as may be needed (CP1) |
| 6201.30 | 0 flagged as certificate data required (CP2), 7 flagged as may be needed (CP1) |
| 6201.40 | 0 flagged as certificate data required (CP2), 7 flagged as may be needed (CP1) |
| 6202.20 | 0 flagged as certificate data required (CP2), 3 flagged as may be needed (CP1) |
| 6202.30 | 0 flagged as certificate data required (CP2), 7 flagged as may be needed (CP1) |
| 6202.40 | 0 flagged as certificate data required (CP2), 7 flagged as may be needed (CP1) |
| 6203.12 | 0 flagged as certificate data required (CP2), 1 flagged as may be needed (CP1) |
| 6203.32 | 0 flagged as certificate data required (CP2), 2 flagged as may be needed (CP1) |
| 6203.33 | 0 flagged as certificate data required (CP2), 3 flagged as may be needed (CP1) |
| 6203.39 | 0 flagged as certificate data required (CP2), 1 flagged as may be needed (CP1) |
| 6203.41 | 0 flagged as certificate data required (CP2), 6 flagged as may be needed (CP1) |
| 6203.42 | 4 flagged as certificate data required (CP2), 18 flagged as may be needed (CP1) |
| 6203.43 | 4 flagged as certificate data required (CP2), 12 flagged as may be needed (CP1) |
| 6203.49 | 4 flagged as certificate data required (CP2), 10 flagged as may be needed (CP1) |
| 6204.13 | 0 flagged as certificate data required (CP2), 1 flagged as may be needed (CP1) |
| 6204.31 | 0 flagged as certificate data required (CP2), 2 flagged as may be needed (CP1) |
| 6204.32 | 0 flagged as certificate data required (CP2), 2 flagged as may be needed (CP1) |
| 6204.33 | 0 flagged as certificate data required (CP2), 2 flagged as may be needed (CP1) |
| 6204.39 | 0 flagged as certificate data required (CP2), 2 flagged as may be needed (CP1) |
| 6204.41 | 0 flagged as certificate data required (CP2), 1 flagged as may be needed (CP1) |
| 6204.42 | 0 flagged as certificate data required (CP2), 3 flagged as may be needed (CP1) |
| 6204.43 | 0 flagged as certificate data required (CP2), 3 flagged as may be needed (CP1) |
| 6204.44 | 0 flagged as certificate data required (CP2), 2 flagged as may be needed (CP1) |
| 6204.51 | 0 flagged as certificate data required (CP2), 1 flagged as may be needed (CP1) |
| 6204.52 | 0 flagged as certificate data required (CP2), 3 flagged as may be needed (CP1) |
| 6204.53 | 0 flagged as certificate data required (CP2), 2 flagged as may be needed (CP1) |
| 6204.59 | 0 flagged as certificate data required (CP2), 2 flagged as may be needed (CP1) |
| 6204.61 | 0 flagged as certificate data required (CP2), 4 flagged as may be needed (CP1) |
| 6204.62 | 0 flagged as certificate data required (CP2), 20 flagged as may be needed (CP1) |
| 6204.63 | 0 flagged as certificate data required (CP2), 14 flagged as may be needed (CP1) |
| 6204.69 | 0 flagged as certificate data required (CP2), 14 flagged as may be needed (CP1) |
| 6205.20 | 0 flagged as certificate data required (CP2), 8 flagged as may be needed (CP1) |
| 6205.30 | 0 flagged as certificate data required (CP2), 7 flagged as may be needed (CP1) |
| 6205.90 | 0 flagged as certificate data required (CP2), 1 flagged as may be needed (CP1) |
| 6206.20 | 0 flagged as certificate data required (CP2), 2 flagged as may be needed (CP1) |
| 6206.30 | 0 flagged as certificate data required (CP2), 4 flagged as may be needed (CP1) |
| 6206.40 | 0 flagged as certificate data required (CP2), 5 flagged as may be needed (CP1) |
| 6208.91 | 0 flagged as certificate data required (CP2), 2 flagged as may be needed (CP1) |
| 6208.92 | 0 flagged as certificate data required (CP2), 2 flagged as may be needed (CP1) |
| 6209.20 | 7 flagged as certificate data required (CP2), 0 flagged as may be needed (CP1) |
| 6209.30 | 6 flagged as certificate data required (CP2), 0 flagged as may be needed (CP1) |
| 6209.90 | 10 flagged as certificate data required (CP2), 0 flagged as may be needed (CP1) |
| 6211.11 | 0 flagged as certificate data required (CP2), 2 flagged as may be needed (CP1) |
| 6211.12 | 0 flagged as certificate data required (CP2), 2 flagged as may be needed (CP1) |
| 6211.32 | 2 flagged as certificate data required (CP2), 4 flagged as may be needed (CP1) |
| 6211.33 | 2 flagged as certificate data required (CP2), 4 flagged as may be needed (CP1) |
| 6211.42 | 0 flagged as certificate data required (CP2), 2 flagged as may be needed (CP1) |
| 6211.43 | 0 flagged as certificate data required (CP2), 2 flagged as may be needed (CP1) |
| 6505.00 | 8 flagged as certificate data required (CP2), 0 flagged as may be needed (CP1) |
Counts are the number of lines CPSC flagged under the subheading in its HTS guidance list (CP2: CPSC Certificate Related Data is Required; CP1: CPSC Certificate Related Data May be Needed). Source: CPSC HTS guidance list.
Sources
- cpsc.gov/Business--Manufacturing/Testing-Certification/Lab-Accreditation/Rules-Requiring-T
- ecfr.gov/current/title-16/part-1610
- ecfr.gov/current/title-16/part-1500/section-1500.91
- ecfr.gov/current/title-16/part-1120/section-1120.3
- cpsc.gov/s3fs-public/20260928eFilingCitationTestingExclusionDisclaimGuidance.pdf
- cpsc.gov/Business--Manufacturing/Testing-Certification/Lab-Accreditation/Rules-Requiring-a
- cpsc.gov/s3fs-public/CPSCGuidanceHTSListforFilingElectronicCertificates10012026.xlsx
Last verified 2026-10-18; pending review by a compliance consultant. General information, not legal advice or a determination for your product.
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