Federal Flammability Standards: 16 CFR Parts 1632 and 1633:
Federal regulations 16 CFR § 1632 and 1633, administered by the U.S. Consumer Product Safety Commission (CPSC), require all mattresses sold in the United States to meet flammability standards. ISPA members may learn more about these standards here. Additionally, the CPSC maintains a business education page.
General Conformity Certificates
Manufacturers and importers of general use products subject to CPSC safety standards (including mattresses) are required to issue a General Conformity Certificate stating compliance with product safety rules (such as Parts 1632 and 1633) and other information to its distributors or retailers.
Manufacturers and importers of children’s products (see below) must issue a Children’s Product Certificate based on test results from a CPSC-accepted laboratory, that their children’s products comply with applicable children’s product safety rules.
Requirements for Children’s Products and Child Care Articles
In addition to the federal flammability standards that apply to all mattresses, several other CPSC-administered requirements apply to mattresses that are considered to be “children’s products” and “child care articles.”
The Consumer Product Safety Improvement Act (CPSIA), enacted in August 2008, set new component content requirements and other requirements for certain children’s products:
For children’s products, no component may contain more than 100 parts per million (ppm) of lead. The law defines a children’s product as a consumer product designed or intended primarily for children 12 years of age or younger. CPSC has granted testing exemptions for inaccessible component parts and the following textile materials:
- Natural fibers (dyed or undyed) including, but not limited to, cotton, kapok, flax, linen, jute, ramie, hemp, kenaf, bamboo, coir, sisal, silk, wool (sheep), alpaca, llama, goat (mohair, cashmere), rabbit (angora), camel, horse, yak, vicuna, qiviut, guanaco;
- Manufactured fibers (dyed or undyed) including, but not limited to, rayon, azlon, lyocell, acetate, triacetate, rubber, polyester, olefin, nylon, acrylic, modacrylic, aramid, spandex.
For those products and components that must be tested and certified for lead, the CPSIA requires manufacturers to use a CPSC-accredited third party or in house testing lab. As of February 8, 2013, manufacturers must conduct sample testing of their products on a periodic basis.
Certain categories of phthalates are limited for use in “child care articles,” which may include mattresses designed or intended for use by children three years of age or younger. A “child care article” may not contain more than 0.1% of DEHP, DBP, and BBP, which are banned on a permanent basis, or DINP, DIDP, and DnOP, which are banned pending further review. Like the lead requirements, manufacturers must use a CPSC-accredited third party or in-house lab to meet the phthalates testing and certification requirements and must conduct periodic sample testing as of February 8, 2013. Only parts that accessible to children that are made from plastic or that conceivably could contain phthalates must be tested.
Manufacturers of children’s products must place a permanent distinguishing mark or label on the product and its packaging that identifies the source of the product, the date of manufacture and more detailed information on the manufacturing process, such as a batch or run number.
Crib Mattress Standard
ISPA led an effort by crib mattress manufacturers to establish a new crib mattress safety standard. This initiative was in response to broader efforts by the CPSC to set new safety standards for a number of juvenile products, including cribs. ISPA led the way in developing a new ASTM voluntary safety standard for crib mattresses that was formally issued in June 2013. The standard sets a size requirement for crib mattresses and establishes a test method for use in measuring the size. The standard also requires that crib mattresses include a label with safety warnings to advise consumers to make sure their crib mattress properly fits within a crib and warnings to help prevent Sudden Infant Death Syndrome (SIDS). The standard is available for purchase from ASTM.
Other Children’s Product Safety Requirements
In addition to the requirements imposed by the CPSIA, certain children’s products list and are also subject to CPSC-administered safety standards.
“Any upholstered product, mattress or cushion which contains stuffing which has been previously used as stuffing in any other upholstered product, mattress or cushion shall have securely attached thereto a substantial tag or label, at least 2 inches by 3 inches in size, and statements thereon conspicuously stamped or printed in the English language and in plain type not less than 1/8 inch high, indicating that the stuffing therein is composed in whole or in part of reused stuffing, secondhand stuffing, previously used stuffing or used stuffing.”