When it comes to clothing, hats, gloves, and shoes are not something you typically think of, but they are considered under that category. This means that you will follow the same process as other clothing like shirts, pants, and dresses.
The great thing is that there isn't a whole lot to be done for most of these items since there are specific exemptions from certain testing and certain labeling for everyone.
Adult Hats, Hair Accessories, Gloves, and Shoes
- Exemption from Flammability testing if it does not cover neck or shoulders under CPSC's 16 CFR Part 1610.
- Exemption from Fiber Content & Manufacturer Identity labeling under FTC's 16 CFR Part 303.
- Exemption from Care information labeling under FTC's 16 CFR Part 423.
- Exemption from Country of Origin labeling under USCBP's 19 CFR Part 134.
For adults, there is nothing to be done other than making them and selling them.
Children's Hats, Hair Accessories, Gloves, and Shoes
Testing
- All non-fabric components (ex. metal, plastic, treated wood) must be tested for Total Lead Content under CPSIA 2008 Sec 101a and CPSC's 16 CFR Part 1500.
- All treated or coated components (ex. vinyl, leather) must be tested for Total Lead Content under CPSIA 2008 Sec 101a and CPSC's 16 CFR Part 1500.
- Certain exemptions from Total Lead Content testing can be found at CPSC's 16 CFR Part 1500.91
- All surface coatings (paint, lacquer, sealant, anything that can be scratched off the surface of the component) must be tested for Lead in Paints and Other Similar Surface Coatings under 16 CFR Part 1303.
- Exemption from Flammability testing if hat does not cover neck or shoulders, gloves aren't longer than 14" in length, and shoes aren't connected to garment under CPSC's 16 CFR Part 1610.
As a registered small batch manufacturer, you do not necessarily have to test for Total Lead Content or Lead in Surface Coatings. You can rely on recent information from your suppliers instead. "Recent" means that the information is no more than a year old.
Labeling
- Exemption from Fiber Content & Manufacturer Identity labeling under FTC's 16 CFR Part 303.
- Exemption from Care information labeling under FTC's 16 CFR Part 423.
- Exemption from Country of Origin labeling under USCBP's 19 CFR Part 134.
- Permanent labels required for children's products under 15 U.S.C. §2063(a)(5)
- Location of production
- Date of production
- Unique batch, run number, or other identifying characteristic (to assist in a recall if necessary)
Location of production, date of production, and unique batch may all be coded such as 0222TN01 for a product made in February 2022, made by a sewing contractor in a specific city in Tennessee. If you are the only person creating the product, location coding is not required.
Documentation of Compliance
- Children's Product Certificate must be created and maintained in the manufacturer's records under CPSC's 16 CFR Part 1110
- Citation to all product safety rules that must be followed for this product
- Identification of manufacturer or importer (your business name and contact information)
- Identification of individual maintaining compliance information (your personal name and contact information)
- Date & Place of manufacture (month, year; City, ST, Country)
- Date & Place of testing, supplier statement information, exemption citations
- Identify any 3rd-party lab that conducted testing if applicable & Small Batch Manufacturer registration number if applicable.
More Assistance
If this was a lot, don't worry, it is and I understand that! That's why I have created a digital book that walks you through the process, step-by-step, in a more conversational tone.
Join my free Facebook group, US Product Safety Compliance.
The Makers Community membership.
Free Checklist.
Free basic product safety course.
