DTF Transfer Safety

Children's products

Who is responsible for what when a transfer goes on a child's garment, what we provide, and how to request documents and a referral.

This page is for anyone who will put a ProTransfers transfer on a garment for a child aged twelve or under and sell it. It explains who the law makes responsible, what the rules actually require, what we can give you, and what we cannot. It is written for the United States; other markets have their own rules.

Who is responsible

Under the Consumer Product Safety Improvement Act, the domestic manufacturer or importer of a children's product must have it tested by a laboratory the Consumer Product Safety Commission has accepted, issue a Children's Product Certificate based on those results, and put a tracking label on the product and its packaging. The CPSC's own guidance for decorated clothing says it plainly: suppliers of blank garments or of inks may have tested their component and may have certified it, and you may be able to rely on that, but you must still issue the certificate for the finished product. The CPSC also says that decorating a general-use blank at a customer's direction can turn it into a children's product, and that whoever directs that final step is the responsible party.

A transfer is a component of your product. We do not make the garment, we do not sell it to the consumer, and we cannot certify a product we did not make.

What the rules require

• Lead. The limit is 100 parts per million of total lead in any accessible part of a children's product, and 90 parts per million for paint and similar surface coatings. CPSC staff have said that heat transfers and screen prints are treated as surface coatings, so plan on the transfer area of a garment being tested to the 90 ppm limit under 16 CFR part 1303. Plain dyed fabric is exempt from lead testing; a fabric with a transfer on it is not.
• Phthalates. The limit of 0.1 percent for eight phthalates applies to plasticised parts of children's toys and of child care articles, which the CPSC defines as products that help a child of three or under sleep or eat. Children's sleepwear and bibs are the examples the CPSC gives. The phthalate limit does not apply to ordinary children's apparel. Our adhesive is a thermoplastic polyurethane rather than a plasticised PVC, and the ink is a water-based pigment ink, so neither is formulated with a phthalate plasticiser; see Wearing and washing for what "formulated without" does and does not mean.
• Tracking labels. The finished product and its packaging must carry the maker's name, the location and date of production, and batch information. That is the garment maker's label, not ours.
• Small-batch manufacturers. A registered small-batch manufacturer gets relief from some third-party testing, but lead in paint and surface coatings is on the list that must always be third-party tested. If you decorate children's garments, expect to test the decorated area at a CPSC-accepted laboratory even as a small batch.

What we provide, and what we do not

The component-part rule, 16 CFR part 1109, says a component supplier may test or certify its component but is not required to, and that a finished-product certifier may rely on a component's test results only when the component in the finished product is identical in all material respects to what was tested.

What we provide today:

• The Product Safety Summary, prepared from the manufacturers' Safety Data Sheets, with composition and classification for every material in a transfer.
• Answers to specific questions about our materials and process.
• A referral to the manufacturer's safety team on request, through our help line.

What we do not provide today:

• A third-party laboratory test report for a finished transfer. We have not commissioned one. If your certification needs one, tell us: it is the single most useful document we could add, and knowing who needs it helps us decide when.
• A Children's Product Certificate, or any certification of our transfers as children's products. Certification is the finished-product maker's act, and under the component-part rule a supplier who certifies takes on a manufacturer's responsibilities for that certification. We would rather give you accurate data than a certificate that means less than it looks.

Sleepwear

Children's sleepwear has its own flammability standards, 16 CFR parts 1615 and 1616, under which the garment maker tests the fabric and every trim and decoration on it. Applying any decoration, including our transfers, to sleepwear changes the garment, and the finished garment must be tested by whoever sells it. We do not recommend applying transfers to children's sleepwear unless you will test the finished garment. Tight-fitting sleepwear and infant sizes are excepted from the sleepwear test but still fall under the general clothing flammability rule. And sleepwear for children of three and under is a child care article, so the phthalate limit above applies to it as well.

Flammability of other clothing

The general clothing flammability rule, 16 CFR part 1610, applies to the garment. Plain-surface fabrics of 2.6 ounces per square yard or more are exempt from testing; many lightweight tees are not. The rule excludes film from its definition of a textile fabric, and a heat-applied film does not create the raised fibre surface that the rule is most concerned with. We are not aware of CPSC guidance that addresses heat transfers specifically, so we say only that: we are not aware of any. We make no flammability claim for a transfer.

Placement

Avoid placements that will sit in prolonged contact with an infant's face or mouth. This is placement advice rather than a finding about the material, and it is the kind of thing a children's-product designer already knows.

Outside the United States

The rules above are American. The European Union's REACH regulation, for instance, requires a supplier of an article to tell its customer when the article contains a substance of very high concern above 0.1 percent by weight. From the manufacturers' documentation we are not aware of any such substance in our transfers; we have not tested for one. If you sell into another market, tell us which, and we will help with what we have.

How to ask

This page is our understanding of the rules as a supplier, checked against the primary texts on the date at the foot of the page. It is not legal advice, and the rules change. Your compliance adviser or a CPSC-accepted laboratory is the right source for how they apply to your product.