Do our cotton fleece hoodies need flammability testing under the US clothing flammability rule?
The standard applies to nearly all clothing. Some fabrics are exempt from testing, but brushed cotton fleece is a raised-surface fabric outside the fibre exemption. Check the rule with a lab.
We import brushed cotton-polyester fleece hoodies and plain cotton jersey tees for adults. A customer asked whether they meet the US flammability standard. Do we need to test them, and what does the rule say?
Main answer
The US Standard for the Flammability of Clothing Textiles, 16 CFR Part 1610, applies to textile fabric or related material ready for use in wearing apparel, including garments finished for consumer use. It classifies fabrics by burning behaviour into Class 1 (normal flammability), Class 2 (intermediate, used for raised-surface fabrics) and Class 3 (rapid and intense burning). The standard says Class 3 textiles are dangerously flammable and shall not be used for clothing. The rule is about the fabric, so it covers adult tees and hoodies too, not only children’s clothes.
What is exempt from testing
The standard lists specific exemptions from testing. Plain surface fabrics, regardless of fibre content, weighing 2.6 ounces per square yard or more are exempt. So are all fabrics, plain or raised, made entirely from acrylic, modacrylic, nylon, olefin, polyester, wool, or combinations of those fibres. Cotton is not on that fibre list. The weight exemption also only covers plain surface fabrics, not fabrics with an intentionally raised surface.
Where fleece falls
The standard defines a raised surface fabric as one with an intentionally raised fibre or yarn surface, such as a pile, nap or tufting. Brushed fleece is raised on at least one side. A fleece made entirely of polyester falls under the fibre exemption, while a cotton or cotton-polyester brushed fleece does not. The rule also mentions sweatshirts with an exposed raised fibre surface inside that can be worn napped side out as an example of exposed parts of a garment. Ask an experienced textile test lab to confirm how your fabric and construction are treated.
Plain jersey tees
A plain cotton jersey with no raised surface at or above the weight limit falls within the plain-surface exemption. A very light fabric below the limit would not.
Certificates and records
Exempt from testing does not mean outside the rule. CPSC has published a statement of enforcement discretion about general conformity certificates for adult apparel that is exempt from testing, and CPSC’s clothing FAQ is the place to confirm current expectations. Check them with your customs broker or compliance adviser. Since July 2026, importers also eFile certificate data for regulated products, so know which certificate covers each style.
What to ask your factory
Ask for fabric composition, whether it is raised or plain, its weight, and any available flammability test report for the fabric. Keep these records by style, and retest if the fabric changes.
Sources and further reading
- eCFR — 16 CFR Part 1610, Standard for the Flammability of Clothing Textiles
- CPSC — Clothing (flammability and other rules): business FAQ
- Federal Register — CPSC statement of enforcement discretion on general certificates for adult wearing apparel exempt from testing (2016)
- CPSC — Flammable Fabrics Act business guidance
Standards and rules are summarised from their published scope or official guidance. Use the current edition and confirm requirements for your market.
Three perspectives on this question
Purchasing perspective
I'd ask the mill for fabric composition, weight and any flammability report for each fleece before we sign off the style.
Merchandising perspective
This does not change how the hoodie looks, but it can add a test and a certificate to the cost of every new fleece.
QC perspective
We'd keep the fabric records and any test report with each style file and flag any fabric change for review.
Working on a similar program?Send your tech pack, fabric references and test requirements. We reply with a quote and the questions we need answered.
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