Are zippers on children’s clothing required to be tested and certified for small parts, sharp points and sharp edges regulations?
A23: Zippers on children’s clothing fall under the scope of 16 CFR 1500.48 (sharp points) and 1500.49 (sharp edges), but they do not fall under the scope of 16 CFR 1501 (small parts), because of the exemption in 1501.3 (d) for children’s clothing and accessories, such as shoe lace holders and buttons. Zippers would fall under this exemption. However, the CPSC continues to recall children’s clothing due to small parts detachment. Therefore, we strongly advise against using this exemption, and we recommend that children’s clothing for children under 3 years of age meet the small parts regulation, both before and after use and abuse testing. Your certificate of conformity should include all three of these regulations. Currently, small parts testing must be performed by a CPSC-accredited third-party lab, such as STR, and compliance cannot be based solely on a manufacturer’s certification, unless backed by third-party testing.
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