Decorations are often the riskiest part of a kids' tee from a chemical point of view. Fabric itself is usually a lower risk for lead, but metallic foils, glitter, rhinestones, studs, coated trims and some inks can contain metals or coatings that need checking. A fabric test report does not cover them.

The lead limits

CPSC guidance states that accessible components of children's products must not contain more than 100 ppm total lead. A rhinestone or a foil on the front of a tee is clearly accessible. Paints and similar surface coatings on children's products have their own lead limit, and some print or coating materials may fall into that category, so ask a CPSC-accepted lab which rules apply to each decoration.

Third-party testing

Children's products subject to these rules need third-party testing by a CPSC-accepted laboratory and a Children's Product Certificate from the importer or domestic manufacturer. CPSC allows component part testing, so a decoration supplier's test reports can sometimes be relied on, if you use due care and follow the component testing rules. CPSC has also determined, in 16 CFR 1500.91, that certain materials do not exceed the lead limits, including dyed or undyed textile fibres. That determination does not extend to after-treatment applications such as screen prints, transfers and decals, so the decorations on your tees still need attention even when the fabric itself does not need lead testing.

Plan the decoration list

List every decorative material on each style: ink system, glitter type, foil, rhinestone supplier and colour, adhesive. Each different material may need its own test. Keeping the number of decoration materials small across the range reduces test cost and risk.

Ask each decoration supplier for the material specification as well as the test report, so you can confirm the tested material is the one actually used on your tees.

Manage supplier changes

CPSC guidance says that if a material change is made after certification, the changed component must be retested and a new certificate issued. A new rhinestone supplier or a different foil counts. Require the factory to get approval before any decoration supplier change.

Practical safety too

Beyond chemistry, check that rhinestones and studs stay attached after washing and pulling. Loose decorations on young children's clothing are a choking concern, so test attachment as well as content.