CPSC extends clothing fire-test paperwork forever—yay?
Published Date: 9/28/2026
Notice
Summary
The Consumer Product Safety Commission is extending its approval to collect info from clothing and vinyl plastic film makers to keep fire safety standards strong. This means manufacturers and importers must keep following the rules to make sure their products aren’t flammable. Comments on this extension are open until October 28, 2026, but no changes or extra costs are expected.
Analyzed Economic Effects
5 provisions identified: 0 benefits, 4 costs, 1 mixed.
Mandatory 3‑Year Test Recordkeeping
If you manufacture, import, distribute, or sell clothing textiles or vinyl plastic film for apparel, you must keep test records that support guaranties and any received guaranties for three years under 16 CFR 1610.38 and 1611.38. CPSC estimates 10,000 firms will create 100,000 records annually (about 10 records per firm), totaling about 100,000 hours for recordkeeping and contributing to a total estimated annual burden of 101,600 hours.
Voluntary Continuing Guaranty Filings
Firms may voluntarily file a continuing guaranty with the Commission using a CPSC form; CPSC estimates 160 firms will file 1,600 forms annually (about 10 forms per filing firm). CPSC assumes each continuing guaranty form takes about one hour to create and submit.
Children's Apparel Must Have Third‑Party Testing
Manufacturers and importers of children's wearing apparel subject to 16 CFR parts 1610 and 1611 must certify compliance in a Children's Product Certificate (CPC) based on testing by a CPSC‑accredited third‑party conformity assessment body.
Import Proofs, Affidavits, and Possible Bonds for Finishing Shipments
If you import wearing apparel or fabrics to the U.S. for finishing or treatment to reduce flammability, you must maintain proof of treatment, provide affidavits to U.S. Customs and Border Protection, and, if required, furnish a performance bond. CPSC assumes fewer than 10 such shipments enter the U.S. annually.
General Certificate of Conformity for Adult Apparel
Manufacturers and importers of general‑use adult wearing apparel that are subject to flammability standards must certify compliance in a written General Certificate of Conformity (GCC) based on testing or a reasonable testing program. CPSC states most GCC burden is covered under OMB control number 3041-0203 and the remainder is negligible.
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