 Hello! In this video, we will be going over CPSC safety requirements for children's cloth diapers. Cloth diapers are items of wearing apparel that are generally subject to flammability requirements under 16 CFR Part 1610, the standard for the flammability of clothing textiles, total lead content and substrate requirements under 15 USC, section 1278A, and lead and paint and surface coating requirements under 16 CFR Part 1303, if applicable. Manufacturers and importers of cloth diapers must certify their products as compliant in a children's product certificate, also known as the CPC. Finally, children's products are required to meet tracking label requirements under 15 USC, section 2063A5. Textiles used in children's wearing apparel must comply with the standard for the flammability of clothing textiles. The fabric must be third-party tested unless the fabric meets an exemption under 16 CFR, section 1610.1D. Fabrics that meet a specific exemption from the standard do not require testing. For the first exemption, plain surface fabrics weighing 2.6 ounces per square yard or more do not need to be tested, regardless of fabric content. Weighing the fabric does not need to be conducted by a lab and you can measure the weight yourself, or check to see if this info is provided on the fabric roll you are using to construct the garment. You will need to keep records of any information you use to determine the weight for a minimum of five years. For the second exemption, plain and raised surface fabrics made entirely of acrylic, mod acrylic, nylon, olefin, polyester, wool, or a combination of these fibers, regardless of weight, are exempt from testing. Fabrics that contain any other fibers other than the six specified would not meet this exemption. Any fabric that is exposed that does not meet one of these exemptions must be tested for compliance to 16 CFR, Part 1610. Part 1610 applies to uncovered or exposed surfaces of an article of wearing apparel. The outer surface of an undergarment, such as a diaper, is considered an uncovered or exposed part of the garment. Any linings that can be exposed when the garment is rolled or worn reversibly are examples of exposed parts. Fabrics used in the inner surface that peek out the side near the leg holes that are different fabrics than the outside will also need to be tested. In this situation, each fabric would need to be tested separately. Where the interior fabric is not exposed, it does not need to be tested. An example of an interior fabric that does not require testing is the interior soaker that clips completely inside the diaper. Polyurethane laminate, or PUL, is commonly used to treat fabrics for water resistance and is often applied to polyester, which is a fiber exempt from testing under 16 CFR, Section 1610.1d2. In scenarios where the PUL is applied to exempt fibers and is not exposed or otherwise accessible, the fabric will not require any further flammability testing. If the PUL is sandwiched on the interior portion between two fabrics and is not accessible to the child's skin, fingers, or mouth, it will be considered inaccessible. Cloth diapers frequently use hook and loop fabric as closures for the diaper. If a diaper contains hook and loop fabric and it is less than 50mm in either direction, it is considered a narrow fabric that is not tested. If the hook and loop fabric is comprised of one of the six exempt fabrics under 16 CFR, Section 1610.1d2, no further testing is required. If the hook and loop fabric covers an area of more than 24 square inches and is not comprised of one of the exempt fabrics, it should be tested as a separate fabric under Part 1610. Children's products are subject to the total lead content requirements of 15 USC, Section 1278a. All accessible component parts must comply with the lead content limit of 100 parts per million. The accessible components must be third-party tested for compliance if no testing determination, exception, or exemption applies. Under 16 CFR, Section 1500.91, the Commission issued a determination that natural and manufactured textiles that are dyed and undyed and that are not treated or adulterated do not need to be tested for lead content. Commission staff considers hook and loop systems to be textiles that are covered by this determination. If the diapers have any fasteners or accessories, including metal or plastic snaps, buttons, or grommets, they will need to be tested separately to certify that they meet the total lead content requirement. PUL is subject to the lead content requirement and must be tested if it is accessible to the child. The PUL is considered inaccessible if the treated side of the fabric is on the interior portion of a diaper composed of at least two fabrics stitched together. Additionally, any painted or coated fasteners and diapers that have screen printing or transfer printing must comply with the lead content limit of 90 parts per million under 16 CFR, Part 1303. Different colors need to be tested because color can affect compliance with the requirements. Children's cloth diapers must be tested for applicable safety requirements, such as flammability, total lead content, and lead and paint requirements at a third-party CPSC-accepted laboratory. You can find a lab at cpsc.gov slash labsearch. However, if you are a qualifying small batch manufacturer, you may be eligible for third-party testing relief for certain requirements. Flammability and total lead content requirements fall under Group B requirements, which means that you may be able to certify compliance in alternate ways beyond third-party testing your product at a CPSC-accepted lab. Such alternatives include first-party testing, which is performed in-house by the domestic manufacturer or importer, testing by a non-CPSC-accepted lab, or by receiving a written assurance of compliance from your producer or supplier. Lead and paint requirements must always be tested at a third-party CPSC-accepted lab regardless of your status as a small batch manufacturer. You can find out more information about whether you qualify as a small batch manufacturer and how to register at cpsc.gov slash small batch. Once manufacturers and importers have received applicable passing test results for their products, and have gathered any additional compliance documentation, they must issue a Children's Product Certificate, also known as a CPC. To learn about how to create a CPC, please watch CPSC's three-part education series for CPCs by visiting CPSC's business education playlist at youtube.com slash uscpsc. Children's products and their packaging are required to have tracking labels. A tracking label is a distinguishing permanent mark that is affixed to the product and its packaging to the extent practicable and provides certain identifying information that is ascertainable, including the manufacturer, importer, and or private labeler, date and location of production, and a batch code or cohort information that helps identify the specific source of the product. To learn more about the tracking label requirement, please watch CPSC's tracking label requirement video by visiting CPSC's business education playlist at youtube.com slash uscpsc. If you're new to product safety or need help, CPSC's regulatory robot is an online tool that will walk you through a series of questions to discover the likely applicable requirements in place for your consumer product. You can access the regulatory robot at business.cpsc.gov slash robot. We also recommend that you check out product safety recalls at cpsc.gov slash recalls. We hope you learned a lot about CPSC requirements for children's cloth diapers. If you have questions about cloth diaper requirements or any other requirements involving your consumer products, please contact the small business ombudsman by visiting cpsc.gov slash smallbiz submitting an inquiry through our contact form at cpsc.gov slash sbo contact calling toll free at 888-531-9070 or emailing us at sbo at cpsc.gov Thanks for watching!