CPSC Drawstring Rules for Children's Clothing: What Amazon Sellers of Kids' Hoodies Must Check

The CPSC drawstring rule for children’s clothing comes down to two size bands. On children’s upper outerwear such as hoodies, sweatshirts and jackets in sizes 2T to 12 or the equivalent, hood and neck drawstrings are not allowed. In sizes 2T to 16 or the equivalent, waist and bottom drawstrings may extend no more than 3 inches outside the drawstring channel when the garment is expanded to its fullest width, with no toggles, knots or other attachments at the free ends, and a continuous string must be bar tacked (CPSC, data checked 2026-10-12).

Garments that miss those requirements sit on CPSC’s substantial product hazard list at 16 CFR 1120.3(b), which brings reporting duties, recall exposure and refused entry at the border. This guide sets out the criteria in CPSC’s own words; it does not decide whether any specific product meets them.

Sources: 16 CFR part 1120 (eCFR, current through the 2026-10-01 issue), CPSC’s Drawstrings in Children’s Upper Outerwear business guidance and its drawstrings FAQ. Data checked 2026-10-12.

What 16 CFR 1120 Says About Drawstrings

Part 1120 is titled “Substantial Product Hazard List.” Besides children’s drawstrings it covers hair dryers, seasonal lighting, extension cords and window coverings.

Section 1120.1 gives the legal basis: under section 15(j) of the Consumer Product Safety Act, listed products “have characteristics whose existence or absence present a substantial product hazard under section 15(a)(2) of the CPSA.” Listed products “are subject to the reporting requirements of section 15(b),” to the recall provisions of sections 15(c) and (d), “and shall be refused entry into the United States under section 17(a)(4) of the CPSA.”

The drawstring entry, section 1120.3(b)(1), covers “Children’s upper outerwear in sizes 2T to 16 or the equivalent, and having one or more drawstrings, that is subject to, but not in conformance with, the requirements of ASTM F 1816-97.”

Section 1120.2(c) defines a drawstring as “a non-retractable cord, ribbon, or tape of any material to pull together parts of upper outerwear to provide for closure.” Section 1120.4 names the standard: ASTM F 1816-97, “Standard Safety Specification for Drawstrings on Children’s Upper Outerwear,” approved June 10, 1997. The part dates from 76 FR 37640 (June 28, 2011); its latest amendment, 87 FR 72886 (November 28, 2022), added window coverings (eCFR, data checked 2026-10-12).

The CPSC business guidance page is an older summary whose disclaimer says it “has not been reviewed or approved by the Commission.” Treat the eCFR text as controlling and the guidance page as the plain-language explanation.

The CPSC Drawstring Rule for Children’s Clothing at a Glance

Data checked 2026-10-12. CPSC staff report 26 deaths and 73 nonfatal incidents associated with neck and hood drawstrings, which the FAQ dates from January 1985 to June 2019. Most involved drawstrings catching on playground slides.

Which Garments Count as Children’s Upper Outerwear

The FAQ quotes ASTM F 1816-97’s definition of upper outerwear: “clothing, such as jackets and sweatshirts, generally intended to be worn on the exterior of other garments.” It adds that “This definition excludes underwear and inner layers,” and that lightweight warm-climate outerwear is included.

Neither CPSC page names hoodies. By that definition, a pullover or zip hoodie in a children’s size is a sweatshirt worn over other clothing, so it sits squarely in the category, as do windbreakers, fleece jackets, parkas and rain jackets.

Outside the standard, per the FAQ:

• Bottoms. “Pants, shorts, and skirts are not intended for the upper portion of the body and are excluded from the scope of the standard.” Kids’ joggers with a drawstring waist fall outside this rule, though other children’s product rules still apply.
• Underwear and inner layers. Excluded by the definition.
• Belts. Not drawstrings under the standard or the 15(j) rule, although the FAQ notes the Commission could act on certain belt styles under other provisions.

On sleepwear, swimwear and costumes, the official pages do not state an answer. If such an item is worn as an outer layer and has a hood cord, check it against the definition rather than assuming an exemption.

Sizing: How 2T to 12 and 2T to 16 Are Read

Most Amazon apparel listings use letter sizes, so the conversion rules in section 1120.3(b)(2) matter. The Commission “may use one or more” of these methods:

1. Letter sizes. Girls’ and boys’ Large (L) equals size 12; XS, S and M equal smaller sizes. Girls’ and boys’ Extra-Large (XL) equals size 16.
2. Bigger labels are not a safe harbor. A hooded garment “labeled as being larger than a size Large (L) does not necessarily mean” it falls outside 2T to 12; the same applies to XL for waist drawstrings.
3. Size ranges. If a label’s range “includes any size that is subject to a requirement,” the whole garment is subject. The regulation’s example: a coat sized 12 through 14 “remains subject to the prohibition of hood and neck area drawstrings,” while a coat sized 13 through 15 is subject only to the waist and bottom rules.
4. No gender label needed. A garment need not say “girls” or “boys” to be covered.
5. Other evidence. The Commission “may use any other evidence” of size equivalence.

For a seller, the size chart, tag, images and title are all evidence of size. A hoodie sold as “Kids XL (14-16)” falls in the waist and bottom band; a combined “Youth L/XL” variant reaches size 12 and so falls in the hood band too.

Hood and Neck Drawstrings: No Cord in Sizes 2T to 12

For sizes 2T to 12 or the equivalent, the FAQ states that ASTM F1816-97 prohibits hood and neck drawstrings. There is no length allowance at the hood. A short cord, a cord with tied ends or a flat ribbon tie at the neck is still a “cord, ribbon, or tape of any material.”

The one exemption is a fully retractable cord. The FAQ says a cord qualifies only if it meets every listed characteristic, including that it “retracts automatically and completely its full length into the garment” after the wearer adjusts and releases it. Protruding cords and free-swinging toggles do not qualify.

Elastic gets a narrow answer: “CPSC recommends that children’s upper outerwear have alternative closures, such as snaps, buttons, Velcro, and elastic.” The FAQ does not say an elastic cord threaded through a hood channel is exempt. Read it as: a sewn-in elastic edge is an alternative closure, while a pull cord made of elastic is still a cord. On purely decorative cords, the official pages do not state an answer.

Waist and Bottom Drawstrings: The 3 Inch Limit, Toggles, Knots and Bar Tacks

In sizes 2T to 16 or the equivalent, waist and hem drawstrings are allowed on three conditions:

• Length. No more than 3 inches outside the drawstring channel, measured with the garment expanded to its fullest width. Measuring with the hem gathered gives a shorter reading than the rule intends.
• Free ends. No toggles, knots or other attachments. The FAQ spells it out: “there can be no cord locks, knots, toggles, or other attachments on waist or bottom drawstrings.”
• Bar tack on continuous strings. A continuous waist or bottom string must be stitched through so it cannot be pulled through its channel.

The bar tack is easy to miss. Without it, a child can pull one end until the other reaches well past 3 inches, so a garment that measures correctly on the hanger may not stay that way.

How a Garment Is Checked

The official pages do not state a step-by-step measuring procedure, and ASTM F 1816-97 is a paid ASTM document not reproduced on CPSC’s site. The CPSC pages still give enough for a check of every style and size:

1. Confirm the category. Worn over other garments and covering the upper body means upper outerwear.
2. Map every size. Use the 1120.3(b)(2) rules. Any variant reaching 12 or L is in the hood band; any reaching 16 or XL is in the waist band.
3. Inspect the hood and neck. In the hood band, no closing cord, ribbon or tape unless it is fully retractable.
4. Measure the waist and hem. Expand to fullest width and measure each end outside the channel.
5. Check ends and tacks. No attachments; a bar tack on any continuous string.
6. Check production samples, not just the approved sample, since trims can change between runs.
7. Match the listing. Images showing a hood cord or toggles on a kids’ size are evidence against the product, whatever the stock looks like.

Consequences, Testing and Certification

A 15(j) listing is not a product safety standard. The FAQ says “A 15(j) rule is not a consumer product safety rule and does not create a consumer product safety standard,” and it does not trigger “an independent testing or certification requirement under section 14(a) of the CPSA.”

Children’s hoodies still need certification for other rules. The FAQ says children’s upper outerwear “is subject to surface coating requirements, lead content limits, testing and certification,” plus tracking labels; see the Amazon Children’s Product Certificate. Flammability is a separate rule, covered in our 16 CFR 1610 guide, and fiber and origin labels fall under FTC textile labeling.

What the 1120.3(b) listing brings, per section 1120.1 and the FAQ:

• Section 15(b) reporting, with civil and possibly criminal penalties for failure to report. See CPSC Section 15(b) reporting for Amazon sellers.
• Recalls. The Commission can order a manufacturer, distributor or retailer to repair, replace or refund. See Amazon product recalls for sellers.
• Refused entry. Such products “must be refused admission into the United States under section 17(a) of the CPSA,” which matters for anyone importing inventory for FBA.

Pre-Listing Checklist

• Garment is upper outerwear (worn over clothing, covers the upper body)
• Every variant mapped to the 2T to 12 and 2T to 16 bands, including letter and range sizes
• No hood or neck drawstrings in variants reaching 12 or L, unless fully retractable
• Waist and hem cords 3 inches or less outside the channel at full width
• No toggles, knots or cord locks on waist or hem cord ends
• Continuous waist or hem strings bar tacked
• Production samples checked, and listing images and size chart match them
• CPC, test reports and tracking labels in place for the other children’s rules

Frequently Asked Questions

Are hood drawstrings banned on all children’s hoodies?

They are prohibited in sizes 2T to 12 or the equivalent, per CPSC’s FAQ. Above size 12 and up to 16, hood cords are outside the prohibition, but waist and hem cords must still meet the 3 inch, no toggles and bar tack rules.

Can a children’s hoodie have knotted drawstring ends at the waist?

Not in sizes 2T to 16 or the equivalent. CPSC says such garments “must be free of toggles, knots, and other attachments at the free ends of drawstrings.”

Is 16 CFR 1120 still in force?

Yes. The eCFR text current through the 2026-10-01 issue still lists children’s upper outerwear at section 1120.3(b), referencing ASTM F 1816-97 (data checked 2026-10-12).

Bottom Line

For every children’s top you list, map each size to the two bands, remove hood and neck cords from anything reaching size 12 or L, and hold waist and hem cords to 3 inches at full width with clean ends and bar tacks. Then keep the CPC and test reports for the other children’s rules. Whether a given garment meets these criteria is for its own inspection to show.