US Apparel Compliance: Flammability, Labeling & Rules¶
Apparel compliance in the United States is deceptively fragmented. The federal requirements are relatively minimal — a flammability standard, a fiber content label, and a country of origin marking. But state-level obligations — California's Proposition 65, the emerging NY Fashion Act, PFAS restrictions across multiple states, and packaging heavy metal rules — add layers of compliance that many apparel importers discover only at the point of enforcement.
This guide maps every US compliance requirement for apparel and textiles, from the federal baseline through the state-level obligations that increasingly define market access.
The Federal Baseline: Flammability, Labeling, and Safety¶
Flammability Standards¶
Every article of apparel sold in the US must comply with the flammability standard applicable to its fabric type and intended use:
| Standard | Applies To | Requirement |
|---|---|---|
| 16 CFR Part 1610 | General wearing apparel (adult and children's everyday clothing) | 45-degree flame spread test; fabrics classified as Class 1 (normal flammability), Class 2 (intermediate), or Class 3 (rapid and intense burning) |
| 16 CFR Part 1611 | Vinyl plastic film apparel | Similar flame spread methodology for plastic film garments |
| 16 CFR Part 1615 | Children's sleepwear (sizes 0-6X) | More stringent standard: fabric must self-extinguish after flame exposure. Requires testing of fabric, seams, and trim |
| 16 CFR Part 1616 | Children's sleepwear (sizes 7-14) | Same stringent standard as Part 1615, applied to larger sizes |
Class 3 fabrics under Part 1610 may not be sold in the US for wearing apparel. This includes certain sheer rayon fabrics, brushed cotton fleece, and some synthetic blends that exhibit rapid surface flash. Testing is required at a CPSC-accepted laboratory for children's sleepwear; for general apparel, a reasonable testing program is required but not necessarily at a CPSC-accepted lab.
A GCC is required for apparel subject to flammability standards. Children's apparel — any garment designed primarily for children 12 and under — requires a CPC instead of a GCC.
FTC Labeling Requirements¶
The Federal Trade Commission enforces three mandatory labeling requirements for apparel:
- Fiber content — Every textile product must be labeled with the generic fiber names and percentages by weight (e.g., "100% Cotton" or "60% Polyester / 40% Rayon"). Fibers present in amounts less than 5% may be designated as "other fiber" unless they have a functional significance.
- Country of origin — Every imported textile product must conspicuously disclose the country where it was manufactured or processed. The label must be in English and permanently affixed.
- Care labeling — Every garment must include a care label with washing, drying, ironing, and bleaching instructions. The label must remain legible and attached for the life of the garment.
These are separate from — and in addition to — CPSC safety requirements. A garment that is correctly labeled under FTC rules but lacks the required GCC or CPC for flammability is still non-compliant.
State-Level Requirements¶
Proposition 65 — Chemical Warnings¶
Apparel frequently triggers Prop 65 for chemicals used in textile production:
| Chemical | Common Source in Apparel |
|---|---|
| Lead | Zippers, snaps, buttons, metallic trims, some dyes and pigments |
| Cadmium | Metallic finishes, jewelry components, some synthetic dyes |
| Phthalates | Printed designs on synthetic fabrics, PVC components, plastic packaging |
| Formaldehyde | Wrinkle-resistant, easy-care, and permanent press finishes |
| Azo dyes / aromatic amines | Certain synthetic dyes that can degrade into listed carcinogens |
A Prop 65 warning must appear on the product, the packaging, or at the point of sale if any listed chemical exceeds the safe harbor level. For apparel, the most reliable approach is to test the final garment — not just the fabric — because trims, fasteners, and applied decorations can introduce chemicals that the base fabric does not contain.
PFAS Restrictions — Performance Fabrics Under Fire¶
Water-resistant, stain-resistant, and performance apparel — outerwear, activewear, uniforms — often contain PFAS-based durable water repellent (DWR) treatments. Multiple states now restrict PFAS in apparel:
- Minnesota: PFAS ban in textile furnishings as of 2025 (Phase 1 of Amara's Law)
- New York: PFAS ban in apparel (enacted 2024, effective 2025)
- California: PFAS ban in textiles (AB 1817, effective 2025 for most categories)
- Maine: Reporting required for intentionally added PFAS; broad ban scheduled for 2030
For apparel brands selling nationally, the practical message is clear: transition to PFAS-free DWR treatments now, or face a fragmented distribution map where the same jacket is legal in one state and prohibited in the next.
See the full guide: [US PFAS State Laws: Maine, Minnesota & Multi-State Compliance]
NY Fashion Act — Supply Chain Due Diligence¶
The New York Fashion Sustainability and Social Accountability Act — if enacted — would require fashion brands with more than $100 million in global revenue doing business in New York to map their supply chains, disclose environmental and social impacts, and set binding GHG reduction targets aligned with the SBTi framework. This is a due diligence and disclosure obligation — not a product safety requirement — but it would fundamentally change the compliance obligations for the largest fashion brands selling in the single largest US apparel market.
See the full guide: [NY Fashion Act: Supply Chain Due Diligence Law]
Packaging and California TPPA¶
The packaging that apparel is sold in — polybags, hang tags, cardboard inserts — must comply with California TPPA heavy metal limits (sum of lead, cadmium, mercury, and hexavalent chromium below 100 ppm). This is the same 19-state standard that applies to all consumer packaging.
US vs. EU Apparel Compliance Comparison¶
| Requirement | US | EU |
|---|---|---|
| Product safety | CPSC flammability (GCC or CPC) | GPSR (General Product Safety Regulation) |
| Chemical restrictions | Prop 65 (CA), state PFAS bans | REACH SVHC + Annex XVII restrictions |
| Fiber labeling | FTC Textile Rules | EU Textile Labeling Regulation (1007/2011) |
| Country of origin | FTC required on product label | Not required on product; customs documentation |
| Care labeling | FTC required, English | EU standard care symbols (ISO 3758) |
| Supply chain due diligence | NY Fashion Act (proposed) | CSDDD (adopted), French LdV (in force) |
| Packaging | CA TPPA (19 states) | EU PPWR |
| Flame retardants | CPSC — particularly for children's sleepwear | REACH restriction on certain flame retardants |
The EU framework is broader — REACH SVHC communication and the EU Textile Labeling Regulation create obligations that have no direct US federal parallel. The US system is more fragmented, with California's Prop 65 and the state PFAS bans creating regional compliance requirements that function as de facto national standards for any brand selling nationally.
Practical Apparel Compliance Checklist¶
- Flammability Testing — 16 CFR 1610 for general apparel. 16 CFR 1615/1616 for children's sleepwear. GCC or CPC issued based on testing.
- FTC Fiber Content Label — Generic fiber names, percentages by weight. Permanently affixed.
- FTC Country of Origin Label — English, permanently affixed, conspicuous.
- FTC Care Label — Washing, drying, ironing, bleaching instructions. Remains legible for garment life.
- Prop 65 Audit — Test finished garment for lead, cadmium, phthalates, formaldehyde. Warning issued if any exceed safe harbor levels.
- PFAS Declaration — Verify water-repellent, stain-resistant, or performance finishes are PFAS-free. Track compliance with state-specific ban deadlines.
- CA TPPA Packaging — Packaging components comply with 100 ppm total heavy metal limit.
- CPC for Children's Apparel — If the garment is designed for children 12 and under, a CPC (not GCC) is required, with third-party testing.
- Tracking Label for Children's Apparel — CPSIA Section 103 tracking label on product and packaging for all children's products.
- NY Fashion Act Monitoring — Track legislative status. Begin supply chain mapping if approaching the $100M revenue threshold.
How Sustalium Simplifies Multi-Framework Apparel Compliance¶
Managing flammability certificates, fiber content compliance, Prop 65 warnings, PFAS declarations, and packaging certificates across an apparel catalog — especially when adult and children's lines have different requirements — requires structured documentation and integrated data management.
Sustalium centralizes apparel compliance:
- GCC / CPC Generator — Produce the correct certificate based on garment type and age grade, with the applicable flammability standard automatically included
- Prop 65 Warning Integration — Link chemical audit data to garment SKUs and generate compliant warnings for California
- PFAS Declaration Builder — Document the PFAS status of every finish and treatment applied to your garments, with automated tracking of state-specific ban deadlines
- FTC Labeling Data Management — Maintain fiber composition, country of origin, and care instructions in a structured format that feeds your label production
- Multi-Framework Apparel Dossier — Your flammability certificate, Prop 65 assessment, PFAS declaration, packaging certificate, and NY Fashion Act supply chain data managed from a single product profile
Don't Let State-Level Requirements Catch You Off Guard
Apparel compliance is no longer just a flammability test and a fiber label. PFAS bans, Prop 65 enforcement, and the emerging NY Fashion Act create a multi-framework compliance landscape. Manage it from one platform.
With Sustalium, build your US apparel compliance dossier for just €10 per document.
Frequently Asked Questions¶
Does every garment require a flammability test?
Yes. 16 CFR Part 1610 applies to all wearing apparel. Certain fabrics (plain surface fabrics weighing more than 2.6 oz per square yard, and certain synthetic fabrics that consistently pass) are exempt from routine testing, but the manufacturer must maintain a reasonable basis for the exemption — usually an initial round of testing confirming the exemption applies.
What is the difference between a GCC and a CPC for apparel?
A GCC covers general adult and children's everyday clothing (ages 13+). A CPC is required for children's apparel — any garment designed primarily for children 12 and under — and requires third-party testing at a CPSC-accepted laboratory for lead, phthalates, and flammability where applicable.
Does the US require REACH-like SVHC declarations for apparel?
No. There is no federal US equivalent to EU REACH SVHC communication (Article 33). The closest framework is California's Prop 65, which requires warnings — not declarations — for listed chemicals above safe harbor levels. Prop 65 is a consumer warning obligation, not a supply chain communication obligation.
Last updated: July 15, 2026