1. Frequent recalls and trade risks need to be prevented

In recent years, recalls related to flame retardant properties of textiles have occurred frequently. In April 2021, the U.S. Consumer Product Safety Commission (CPSC) and Health Canada announced a joint recall of a number of children's bathrobes, involving related products sold in the North American market from April 2014 to November 2020. Among them, the total number of recalls in the U.S. market reached 55,700, and the total number of recalls in the Canadian market reached 3,900. The main reason for the recall is that these products do not meet the textile flammability standards of the United States and Canada, and there is a risk of burns to children.

Since 2018, the United States and Canada have implemented more than 30 recalls involving children's pajamas, adult jackets, scarves, mattresses and other products due to non-compliance with the flammability standards of the Flammable Fabrics Act and related regulations. These incidents have caused the relevant companies to suffer huge losses such as returns, compensation, and order interruptions. Therefore, the flame retardant properties of textiles are not only related to consumer safety, but also directly affect the trade risks of enterprises.

2. What products are covered by the Flammable Fabrics Act?

The Flammable Fabrics Act was enacted in 1953 and has been updated several times. The Act gives the U.S. Consumer Product Safety Commission the responsibility and power to investigate, recall and impose penalties on dangerous flammable fabrics. The Flammable Fabrics Act and its associated federal regulations (CFR) cover most fabric products such as adult and children's clothing, children's pajamas, carpets and mats, mattresses, etc.

Compared with the EU and other markets, the United States has stricter regulation on the flame retardant properties of textiles and clothing. Fabrics entering the US market must meet the requirements of the Flammable Fabrics Act and related regulatory standards. In addition to being investigated and recalled, those who violate the requirements of the Act may also face civil fines of no more than US$100,000 per time and no more than US$15 million in total.

3. Flammability standards for general clothing

The flammability of regular clothing fabrics for adults or children must comply with the Class 1 and 2 requirements specified in the U.S. Federal Regulations 16CFR1610. Samples need to be tested twice before and after washing and dry cleaning, and the lower result is classified as follows:

• Class 1 (Normal Combustibility): For plain surface fabrics, the burning time is 3.5 seconds or more; for fabrics with raised surface, the burning time is 7 seconds or more.
• Class 2 (medium flammability): Burning time is 4-7 seconds. This classification applies only to fabrics with raised dry surfaces.
• Class 3 (fast burning): The burning time of fabrics with plain surface is less than 3.5 seconds, and the burning time of fabrics with raised surface is less than 4 seconds.

NOTE: Class 3 plain or raised surface fabrics are not permitted for sale in the United States.

4. Flammability Standards for Children's Pajamas

Because children have a weak sense of self-safety, the United States has higher requirements for children's pajamas, which must meet the flame retardant requirements specified in 16CFR1615 and 16CFR1616. Canada also has similar regulatory requirements for children's pajamas.

The testing of children's pajamas requires sampling of different parts of the garment, including the decorations, and testing under a specific flame and measuring the resulting "scorch length". Each group of samples is tested twice, including newly produced (or washed once) samples and samples after 50 washes.

However, sleepwear for infants aged 0-9 months is exempt from testing if it meets the specific tight-fitting size standards specified in CFR regulations.

5. Ingredients, weight, and craftsmanship: pay attention to the source control

The main reason for the fabric flammability failure is that some companies do not understand the relevant regulations and standards of the United States, Canada and other countries, and do not pay close attention to the selection and processing of fabrics. For example, raw materials without proper flame retardant treatment, fabrics that are too thin and loose, and the use of flammable accessories may lead to non-compliance with flammability.

Generally, untreated natural fibers (such as cotton and linen) have the highest flammability, while synthetic fibers (such as polyester, acrylic, etc.) usually meet the Class 1 flammability standard. Since the test methods of different countries also vary, the same fabric may have different results under different methods.

6. Customs reminds textile and clothing export enterprises

1. Raise awareness of safety regulations: Pay close attention to the textile and clothing safety standards of importing countries, communicate with customers in advance when accepting orders, and clarify quality requirements.
2. Strengthen source control：Choose compliant fabrics and adopt appropriate weaving methods to avoid problems such as flame retardancy failure due to design defects.
3. Do a good job of sample testing：Because of differences in regulations and standards among countries, before exporting, you must entrust a professional third-party testing agency to conduct testing and issue a report, especially the special flammability standards for children's pajamas in the United States, Canada and other countries should be paid special attention.

Through the above measures, enterprises can effectively reduce the trade risks caused by non-compliance with the flammability of textiles and ensure the smooth progress of export business.