This is an extremely common question when it comes to making clothing because all clothing, regardless of size, must conform to the Flammability of Wearing Apparel regulation (16 CFR Part 1610).
The problem is that the definition of "raised surfaced" can be unclear!
"Raised" is a material that has an intentionally raised fiber such that has been brushed or sheared and has pile, napping, or tufting. This includes the loops of Terry materials and the soft brushing of flannels.
I like to think of the material as having tiny fiber fingers that want to grab a flame source. Some common raised surfaced materials are:
- Boucle
- Chamois
- Chenille
- Corduroy
- Felt
- Flannel / Flannelette
- Fleece / Reverse Fleece
- Flocked finish
- Moleskin
- Peach finish
- Sherpa
- Suede
- Terry
- Velour
- Velvet
- Velveteen
Materials that you might think are be raised but aren't
- Bird's Eye
- Bullet
- Cable or Chunky Knit / Weave
- Chiffon (includes toile)
- Crepe (includes Canton, Crinkle, Georgette, Moroccan, Plisse)
- Denim
- Jacquard (includes Brocade, Damask)
- Lace (includes mesh, Raschel knit, Tulle)
- Lame
- Liverpool
- Metalesse
- Oxford
- Poplin
- Rib knit
- Seersucker
- Shirred / Smocked
- Sweater Knit
- Taffeta
- Twill (includes Gabardine, Herringbone, Tweed)
- Waffle
Exemptions?
If you have a raised material, don't fret yet about testing! You may actually still be exempt from testing or from searching for a supplier with testing.
If you are making any of the following types of clothing, your product (and thus the material), is automatically exempt from testing.
- Gloves - Under 14" in length and not attached to a garment
- Hats - That do not cover the neck, face, or shoulders (includes hair accessories)
- Shoes - That are not attached to a garment (includes slippers, booties, and other footwear)
If your raised material is made of one or more of ONLY the following fibers, it is automatically exempt from testing.
- Acrylic
- Modacrylic
- Nylon
- Olefin
- Polyester
- Wool
If you are using the material in a way that would make the raised side unexposed to air when worn, it is automatically exempt from testing.
- Snap-able Cloth Diapers
- Hoodies with the hood lined
- Pants/shirts that are not cuffed outwards
- Cardigans
- Rolled cuffs
- Sweatshirts (they are considered capable of being worn napped side out*)
- Zip Ups
If you've come to this point and still have no exemption, then you have one more decision:
- Don't use the material for clothing
- Contact your supplier and hope they've had testing (result should be Class I or Class II)
- Test on your own (result should be Class I or Class II)
- *Make sure your marketing doesn't include any ideas of wearing the garment in a way that would expose the raised surface side & watch that your consumers aren't frequently wearing the garment in a way that would expose the raised surface side. This is not necessarily CPSC-specific guidance, but we have spoken with agents that have said this could be an option if we'd like to make that choice.
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.
