Textiles Compliance: Lead Testing, CPSIA, and Material Requirements
You hand-dye fabrics, sew children's clothing, or create hand-painted textiles. You sell on Etsy with amazing customer feedback. But are you compliant with CPSIA (Consumer Product Safety Act) and lead testing requirements? Textiles—especially anything marketed for or likely to be used by children—are heavily regulated. The Consumer Product Safety Commission (CPSC) requires lead and phthalate testing for certain products. Non-compliance means your products can be seized and you can face penalties. This guide explains which textiles need testing, how much it costs, where to get tested, and what compliance actually requires.
CPSIA: What You Need to Know
CPSIA: Consumer Product Safety Improvement Act. Federal law that sets safety standards for products marketed to or intended for children under 12.
Key requirement: Children's products (clothing, toys, bedding, etc.) must be tested for lead and phthalates and certified safe before sale.
Who Is CPSIA Enforced By?
CPSC (Consumer Product Safety Commission): Federal agency that investigates violations, recalls products, and can impose penalties.
Etsy and Amazon: Both enforce CPSIA in their policies. Violations result in listing removal and possible account suspension.
State attorneys general: Can also pursue violations.
Real Enforcement
The CPSC actively investigates children's products on Etsy and Amazon. If your product is marketed for or likely to appeal to children but lacks CPSIA certification, you're at risk of enforcement.
Which Textile Products Require Testing?
Products That REQUIRE Testing
If your textile product is marketed for or intended for children under 12:
- ✗ Children's clothing (dresses, shirts, pants, jackets)
- ✗ Baby items (swaddles, sleep sacks, blankets marked for babies)
- ✗ Children's bedding (sheets, pillowcases, comforters marked for kids)
- ✗ Hand-painted or printed fabrics for children (if paint/dye contains lead or phthalates)
- ✗ Children's accessories (hats, scarves, mittens for kids)
Products That Typically DON'T Require Testing
- ✓ Adult clothing (dresses, shirts marketed for adults)
- ✓ Home décor textiles (pillows, wall hangings, blankets marketed for adults)
- ✓ Accessories for adults (scarves, shawls, blankets marketed for grown-ups)
- ✓ Raw undyed fabrics (if no dye or paint that contains lead/phthalates)
Critical: Marketing Determines Requirements
You don't have to explicitly target children. If your product is the type typically used by children (a small-sized dress, for example), CPSIA applies even if you call it "vintage" or "unisex."
Lead and Phthalate Testing: What Gets Tested
1. Lead (Pb) Testing
Limit: Lead content must not exceed 100 ppm (parts per million) for paint or coating on textiles, and 100 ppm for the material itself.
Sources of lead in textiles:
- • Lead in dyes (some imported or vintage dyes may contain lead)
- • Lead in paint or hand-painting used on fabric
- • Lead in natural materials (some mineral-based dyes)
- • Lead in threads or trims used in construction
2. Phthalate Testing
Limit: Phthalates must not exceed 1,000 ppm (parts per million) in any product component. The six regulated phthalates are: DEHP, DBP, and BBP.
Sources of phthalates in textiles:
- • Plastisol inks used in screen printing
- • Vinyl coatings on fabric
- • Some synthetic dyes
- • Elastics or other elastic components
Good news: Natural dyes and high-quality synthetic dyes typically don't contain phthalates. Water-based inks don't contain phthalates. Phthalates are usually only a concern if you're using vinyl/plastisol materials.
Testing Process and Costs
How Testing Works
- Select a CPSC-accredited lab: You must use a lab certified by the CPSC to test children's products
- Submit samples: Send your textile product to the lab (usually 3-5 samples per product)
- Lab tests for lead and phthalates: Takes 1-2 weeks
- Receive results: Lab provides test report showing whether your product passes or fails
- Create Children's Product Certificate (CPC): If testing passes, you create a CPC document certifying the product is safe
Testing Costs
Typical Cost Breakdown
- • Per-product testing: $300-$800 per product (depends on what's tested)
- • Multiple color variations: Each color may need separate testing (~$300-500 each)
- • Rush testing: Extra $100-200 for faster turnaround
- • CPC certificate: Usually included with testing; sometimes ~$50-100
Real example: If you make hand-dyed children's clothing with 3 different color patterns, you might need to test each color separately, costing $900-$2,400 total.
Finding an Accredited Lab
Search the CPSC Accredited Lab Database for labs in your area or that offer shipping services.
Popular options for small makers:
- • TÜV Rheinland: Works with small businesses, offers affordable testing
- • SGS: Large testing company with locations nationwide
- • Local university labs: Sometimes offer testing at reduced rates
- • State health departments: Some offer or refer to affordable testing
How to Reduce Testing Costs
1. Use Certified Safe Materials
If your dyes or inks come with certifications that they're lead and phthalate-free, you have less risk. Document this.
2. Test Once, Certify Multiple Products
If you use the exact same dye/materials but in different product styles (same red dye in both a dress and a shirt), you might only need to test the material once, not each product.
3. Batch Test by Color
Group products by dye color/batch. If all your "red" products use the same dye batch, test one red product and it covers all red items.
4. Market Only for Adults
The most effective cost-reduction strategy: If you market products clearly for adults (in product descriptions, size ranges, photos), CPSIA may not apply.
Example: "Women's oversized hand-dyed shirt" marketed for adults doesn't require CPSIA testing, even if a child could technically wear it.
Care Labels and Material Disclosure
All textile products must include proper care instructions labels.
Required labeling:
- • Fiber content: "100% cotton," "80% wool, 20% nylon," etc.
- • Care instructions: "Hand wash cold," "Machine wash warm," "Dry clean only," etc.
- • Manufacturer/distributor name and address
- • Country of origin: "Made in USA," "Made in India," etc.
For children's products with CPSIA testing: Include the Children's Product Certificate number or reference on your Etsy/Amazon listing.
Textile Compliance Checklist
Key Takeaways
- CPSIA applies to products marketed for or likely to be used by children under 12. Marketing matters more than the product itself.
- Testing costs $300-800 per product color. Multiple colors = multiple tests.
- Use a CPSC-accredited lab only. No exceptions—testing from non-accredited labs won't satisfy compliance.
- Marketing for adults can avoid testing. If you clearly market products for adults, CPSIA may not apply even if kids could wear them.
- Proper care labels and fiber content are required regardless. This is separate from CPSIA testing.
- Etsy and Amazon enforce CPSIA strictly. Non-compliant listings get removed and can result in account suspension.
Other Craft-Specific Compliance Guides
Related Regulatory Guides
External Resources
Track Your Textile Compliance
Testing dates, lab results, Children's Product Certificates, care labels, material sourcing—managing textile compliance documentation is complex. TrueCraft helps textile makers track testing status, certification documents, and compliance deadlines.
Start Free