Kids clothing manufacturers: what a children's line adds to the order

What a kids clothing manufacturer does

A kids clothing factory cuts and sews like any garment factory, on a longer size run. Baby sizes are graded in months; toddler, kids and youth sizes follow, each with its own block pattern. Baby styles carry more snaps and closures, and kids' styles add appliques, glitter and novelty trims that adult basics rarely carry. The cut and sew manufacturers page covers patterns, grading and sampling, which work the same way here. A long size run also spreads a per-style MOQ thin, so ask whether the minimum applies per style or per size.

A kids spec needs a few lines an adult spec can skip. Say whether snaps are plastic or metal, since that decides which tests they need. Name the neck opening, such as an envelope neck on baby tees, and any flat or covered seams against the skin. Say whether care labels are sewn in or printed tagless, and where the tracking code goes. Give a height for every size in the size chart, which the tariff section below also needs.

The bigger change is the paperwork that the Consumer Product Safety Improvement Act (CPSIA) rules call for. Most of what that paperwork needs comes from the factory, so its records decide how easily you can prove compliance.

Which styles count as children's products

The lead, testing, certificate and tracking label rules turn on one definition: a consumer product designed or intended primarily for children 12 years of age or younger^[1]. Calling a style adult on the hangtag or in the listing does not settle it. Under the CPSC's interpretation, a product can still be regulated as a children's product, whatever its maker says, if its primary appeal is to children 12 or younger, for example through child sizing^[2].

The rule lists signs such as small sizes an average adult would find uncomfortable, colors such as pinks, blues and bright primary colors, and motifs such as animals, insects, small vehicles and alphabets^[2]. A youth-sized tee with a cartoon print is likely to count. Record the age grade of every style in the tech pack, because it sets the test plan and the labels before the first sample.

Where each rule applies

Each rule has its own reach, by age, by size or by garment type. A youth line can sit inside one rule and outside the next.

Trims and prints on kids and baby styles: lead, phthalates and pull tests

As the cut and sew page sets out, the CPSC lists dyed fabric with no other treatment among materials that do not exceed the lead limits. A screen print, transfer or coating is not on that list. The tests fall mostly on what is sewn or printed on: snaps, zipper pulls, buttons, vinyl, glitter or sequin appliques, and print inks.

The total lead limit, 100 ppm^[8], applies to the material of every accessible part. A separate limit, 0.009 percent^[9], covers paint and similar surface coatings. The rule's definition of paint leaves out printing inks, and materials that become part of the substrate or are bonded to it, such as by electroplating^[10]. So ask your lab which limit and test method each print and plated trim gets. Plating does not hide the base metal: paint, coatings and electroplating do not count as a barrier that makes lead beneath them inaccessible to a child^[11].

A fabric cover helps less than it seems. Under the rule, a part covered by fabric that passes the use and abuse tests counts as inaccessible, unless the product or that part is under 5 centimeters in one dimension^[11]. A fabric-covered button is usually far smaller than that, so the cover does not make its core inaccessible, and the core needs testing too.

A trim supplier's reports can carry part of the load. The rule lets a certifier rely on third-party lead tests of each accessible component part, as long as which parts are inaccessible is judged on the finished product^[12]. Those reports count only for a component part identical in all material respects to the one used in the finished product, and only if the tested parts are traceable^[13]. Ask the factory for each supplier's report. Check that it gives, among the items the rule lists, the part tested, its lot or batch, the rules and test methods, the test dates, the results and who ran each test, with that party's attestation, plus records that support traceability^[13]. The quality control guide covers the periodic tests and the retest that a change of trim supplier can trigger.

Phthalates come in where a garment counts as a child care article, as defined in the table above. Pajamas for toddlers within that age limit can count, as can baby sleepwear and bibs. For those, the rule bars more than 0.1 percent of any of eight listed phthalates in any plasticized component part of a children's toy or child care article^[14]. The CPSC lists polypropylene, polyethylene, four grades of polystyrene and ABS, each with listed additives, as within the phthalate limits, so parts made of them need no third-party phthalate test^[15]. Other plastics can need one: accessible parts made with a plastic or additive not on that list, and plasticized or able to contain phthalates, must be third-party tested^[15]. Standard plastisol ink is plasticized PVC, which is not on the list, so a plastisol print on a child care article needs a third-party phthalate test. Ask the trim supplier which resin its plastic snaps are made of.

Buttons and snaps on clothing escape the small parts test, but a snap that pulls off a baby's garment can still be a choking risk. Have the snaps and buttons on every baby style pull-tested, and keep the results in the style file. Some states set chemical limits of their own for children's products, so tell your lab which states you sell in.

Flammability: everyday clothes, then sleepwear

Children's clothing falls under the general clothing flammability standard, except sleepwear within the size ranges of the two sleepwear standards. It does not apply to hats, gloves up to 14 inches long and footwear, each within limits, such as not forming part of another garment, and interlining fabrics^[16]. Testing exemptions cover plain surface fabrics, regardless of fiber content, weighing 2.6 ounces per square yard or more^[17], and fabrics of any weight made entirely from one or more of these fibers: acrylic, modacrylic, nylon, olefin, polyester, wool^[17]. On a children's style, a fabric outside the exemptions needs a third-party test; the CPSC lists the clothing flammability standard, 16 CFR part 1610, among the rules for which it accepts third-party labs^[18]. Brushed fleece with any cotton, rayon or spandex in it, and very light cotton such as some gauze, are common cases. Where a style relies on an exemption, the certificate states the testing exclusion it relies on, in place of the date and place of testing for that rule^[19].

Sleepwear within those size ranges has standards of its own, which take the general standard's place: in sizes up to 6X, the sleepwear standard supersedes the clothing textiles and vinyl film standards for sleepwear items^[20], and the standard for sizes 7 through 14 does the same^[6]. In the younger sizes' standard, children's sleepwear means any garment up to and including size 6X, such as pajamas, nightgowns or robes, intended mainly for sleeping or related activities; diapers and underwear are excluded, among others^[21]. To judge whether a style is sleepwear, the CPSC's policy weighs the garment's suitability for sleep, how it is distributed and promoted, and how likely children are to wear it mainly for sleeping, as guidelines rather than required elements^[22]. So calling pajamas loungewear does not take them out of the rule.

The standards exclude some snug-fitting garments, and the younger sizes' standard some infant garments, on strict conditions that the cut and sew page sets out. An excluded style, or sleepwear above those sizes, falls back under the general standard, and snug-fitting styles carry a set hangtag and label. If a style is not excluded, the tests below apply.

Both sleepwear standards test the garment as sewn, not only the fabric roll. Prototype tests take three samples (15 specimens) for the longest seam type, for each other seam type 10 inches or longer, and for each type of trim^[23]. So the seams and trims in the tech pack are part of what passes. A garment production unit is up to 500 dozen finished garments that stay the same except for size, trim, findings, color and print^[21]. The CPSC lists the two children's sleepwear standards, 16 CFR parts 1615 and 1616, among the rules for which it accepts third-party labs^[18], so the tests behind the certificate go to an accepted lab whose scope covers them. Agree with the lab and the factory who runs the unit tests.

If you import the line, the records duty is yours as well as the factory's. Keep copies of the prototype and unit test records, and an untested garment from each style, for the retention period in the table. Keep the seam types and trims of an approved prototype fixed in bulk.

Drawstrings and the size label

The tech pack guide sets out the sizes the drawstring standard covers. It bars hood and neck cords in the smaller sizes and limits waist and hem cords, and the CPSC treats a garment that fails it as a substantial product hazard. For a cord-free spec, and for how a size Large maps to a size number, see the hoodie manufacturers page.

Size labels can pull a style into the rule. Among the sizing methods the CPSC may use, girls' and boys' size XL equal size 16, and a waist or bottom drawstring style labelled above XL can still fall within 2T to 16^[32]. Ranges count too: a size range is covered if any size in it is, so a coat sized 12 through 14 still may not have hood and neck drawstrings^[32]. Decide the size labels when you write the tech pack, and check the cords on a sample from each size band before bulk.

Tariff lines for baby and kids styles

Baby clothes have their own headings, so a style's tariff line can change with its size run. Knit babies' garments are articles for young children of a body height not exceeding 86 centimeters, and a knit garment that could fall in heading 6111 or another heading of the knit chapter goes to 6111^[33]. The woven chapter applies the same 86 centimeter definition and the same priority for heading 6209, the woven babies' heading^[34]. So a knit tee for a baby within that height goes under the babies' heading rather than the T-shirt heading.

The note draws the line by body height, so give your customs broker the size chart with the height for each size, and ask how the edge sizes will be read. For the babies' heading, the knit chapter also defines a set: two or more different garments of headings 6111, 6209 or 6505 imported together, of corresponding sizes and intended to be worn together by the same person^[33]. Tell your broker when pieces are imported together as a set, since that can change the line.

Above baby sizes, kids' styles go under the same headings as adult styles. Where a heading is split into men's or boys' and women's or girls', the cut and sew page explains how the closure and cut decide. To turn the line into a landed cost, use the import duty guide.

The certificate and the factory's records

For a children's style made abroad, the importer^[35] issues the Children's Product Certificate (CPC). The rule means the importer of record, who may be an owner, purchaser or authorized customs broker^[36]. If you are the importer of record, that is you; on delivered duty paid terms, confirm who is. For each rule that needs a test, the certificate must be based on test results from a third-party, CPSC-accepted laboratory^[37].

Some of what the certificate must state is yours; much of it comes from the factory. It needs at least one unique identifier, such as a GTIN, model number, SKU or UPC, with a description that matches the product to it^[19], which you assign. From the factory it needs the month and year of manufacture, and the manufacturer's name, street address, city, state or province, country or administrative region, email address and telephone number^[19]. Get the sewing plant's details in writing for every order. The certifier also must eFile the certificate data when the entry is filed, for finished products made outside the United States and entered for consumption or warehousing^[38]. Mail is different: for goods imported by mail, the certificate data goes into the CPSC's Product Registry before they arrive^[38]. So collect the factory's data before the goods ship, not when they land.

The tracking label ties a garment back to that record. To the extent practicable, its permanent marks on the garment and its packaging must let you find the location and date of production and the batch or run^[39]. They must also let buyers find the manufacturer or private labeler, the location and date of production, and cohort information such as the batch or run number^[39]. Agree with the factory what goes on the care label or a separate label: your company name, or a brand name buyers can trace to it, the production city and country, and the month and year in plain words, next to the lot code. Use the same details on the polybag and carton. Who carries the testing duty is explained in the clothing brand guide; the label rules every garment shares are in the tech pack guide.

Before you pick a kids clothing factory

A factory can sew a children's line well and still leave you without the records. Ask each one:

• Have you shipped children's wear to the US before? Can you show a recent trim test report that names the trim and its lot, from a CPSC-accepted lab whose scope covers that test?
• Who supplies your snaps, zippers, buttons and print inks? Will you tell me before you change any of them?
• How do you mark each production lot so the tracking label, the certificate and the carton match?
• For sleepwear: have you produced to the children's sleepwear standards? Who runs the prototype and unit tests, how do you number the units on the labels, and will you send copies of the records with each shipment?
• Can you pull-test snaps and buttons on baby styles in your own quality room?

A company appears on this page when its own website says it makes kids clothing and it has operated for at least a year. Each card dates that website check, and the methodology explains the full standard. Test reports and lot records fall outside it, so request them.

A trading company can quote a children's line without knowing which plant will sew it, and then you cannot fill in the certificate's place of manufacture. Approve a pre-production sample made with the tested trims. Book a quality inspection at an agreed AQL before the balance is paid, and have it check the tracking labels and cords against the tech pack.

Getting matched with kids clothing manufacturers

Open your request with a link to the tech pack, or to a photo of a garment whose fit you like, plus the age grade and size run of each style. List the fabric and fiber content, the trims and who supplies them, any prints, and whether any style is sleepwear. Say how many units you want of each style, color and size, and when you need them shipped. We read the age grades, size runs and quantities, and introduce you by name to kids clothing manufacturers that fit; if none does, we say so. Brands pay nothing, and the manufacturers quote you directly. Once we offer it, manufacturers can pay for a Featured placement, labelled as paid. Paying for placement does not change who we shortlist, though a Featured manufacturer may receive your details sooner if you agree to share them, as how it works explains.