Two federal flammability standards apply to mattresses sold in the US. 16 CFR part 1632 is a cigarette test: each cigarette location passes only if the char is no more than 2 inches (5.1 cm) from the nearest point of the cigarette. 16 CFR part 1633 is a 30-minute open-flame test: peak heat release must stay at or under 200 kW and total heat release in the first 10 minutes at or under 15 MJ. CPSC’s business guidance says mattresses “are subject to both” parts, while mattress pads are subject to part 1632 only (CPSC, data checked 2026-10-13).
That covers adult, youth, crib and bunk bed mattresses and futons listed on Amazon. This guide gives the scope tests, labels, records and certificate in the regulation’s terms; it does not decide whether a given product is covered or compliant.
Sources: CPSC Mattresses business guidance, 16 CFR part 1632 and 16 CFR part 1633 (Code of Federal Regulations, edition revised as of January 1, 2025, via govinfo), the Federal Register final rule for part 1633 (71 FR 13472), and CPSC’s 2020 Interim Enforcement Policy for part 1632. Data checked 2026-10-13.
The Two Mattress Flammability Standards at a Glance
| 16 CFR 1632 | 16 CFR 1633 | |
|---|---|---|
| Hazard | Smoldering cigarette | Open flame |
| Applies to | Mattresses and mattress pads | Mattress sets |
| Ignition source | Standard Reference Material cigarette (SRM 1196a in the 2025 CFR text) | Two T-shaped propane burners |
| Pass line | Char no more than 2 in (5.1 cm) at every cigarette location | Peak heat release ≤ 200 kW in 30 min; total ≤ 15 MJ in first 10 min |
| Prototype sample | Six surfaces (at least three mattresses if both sides testable) | Three specimens, no smaller than twin size |
| Label | Month and year of manufacture, location of manufacturer | Seven fixed elements, English only |
| Records kept | While prototype in production, plus 3 years | While prototype in production, plus 3 years |
Both are Flammable Fabrics Act standards. Part 1633 took effect July 1, 2007 and, per the Federal Register, “applies to mattress sets manufactured, imported, or renovated on or after that date.”
Mattress, Mattress Pad, or Neither
Mattress. Section 1632.1(a) defines it as “a ticking filled with a resilient material used alone or in combination with other products intended or promoted for sleeping upon.” Both parts list adult, youth, crib (including portable crib) and bunk bed mattresses, futons, and detachable mattresses in upholstered furniture such as sofa beds, day beds and trundle beds. Part 1633 adds flip chairs without a permanent back or arms and sleeper chairs.
Mattress pad. Section 1632.1(b): “a thin, flat mat or cushion, and/or ticking filled with resilient material for use on top of a mattress.” It includes convoluted foam pads “totally enclosed in ticking” and excludes those that are not.
Mattress set. Section 1633.2(c): “either a mattress and foundation labeled by the manufacturer for sale as a set, or a mattress labeled by the manufacturer for sale without any foundation.” A mattress shipped alone in a box is therefore a mattress set for part 1633.
Excluded. Both parts exclude sleeping bags, pillows, water beds and air mattresses with no upholstery material between ticking and core, and juvenile product pads such as stroller, carriage, playpen and dressing table pads, plus crib bumpers. Section 1633.2(a)(2) also excludes mattress pads and “mattress toppers (items with resilient filling, with or without ticking, intended to be used with or on top of a mattress).”
That topper exclusion is in part 1633 only. Part 1632 does not use the word “topper,” and CPSC’s page does not say how part 1632 treats one, so compare the product against the part 1632 mattress pad definition.
16 CFR 1632: The Cigarette Test
Part 1632 requires prototype testing “before selling in commerce or introducing in commerce” any covered mattress or pad. Under section 1632.2(c)(1), importers are deemed manufacturers.
How the test runs (section 1632.4). Mattresses, laundered sheets and cigarettes are conditioned above 18 °C (65 °F) and below 55 percent relative humidity for at least 48 continuous hours. Each test surface gets at least 18 cigarettes, 9 on the bare mattress and 9 between two sheets, across smooth, tape edge and quilted or tufted locations where they exist. A prototype is accepted only if every location on all six surfaces passes the 2-inch char line.
Enforcement discretion on surfaces. CPSC’s 2020 Interim Enforcement Policy, effective September 8, 2020 “until further notice,” says mattress manufacturers and importers “may continue testing only 2 mattress surfaces for newly developed mattress prototypes” using SRM 1196 or SRM 1196a cigarettes, while “Mattress pad manufacturers are required to test six surfaces”. It supersedes the May 15, 2006 policy that first allowed the reduction.
Fire-retardant pads (section 1632.5). Pads with a chemical fire retardant are tested after 10 wash-and-dry cycles, unless not intended to be laundered.
Ticking classes (section 1632.6). An optional test sorts ticking into Class A (a barrier to cigarette ignition), Class B (no effect) or Class C (a potential contributor). Class A ticking can be swapped onto any qualified prototype without retesting; Class C only onto a prototype qualified with that same ticking.
16 CFR 1633: The Open-Flame Test
Section 1633.3(b) sets two criteria for the 30-minute test: peak heat release “shall not exceed 200 kilowatts” at any time, and total heat release “shall not exceed 15 megajoules” in the first 10 minutes. Heat release is measured by oxygen consumption calorimetry.
Qualification (section 1633.4). Three specimens of each prototype must pass before any mattress set based on it is sold. If any one fails, the prototype is not qualified. Specimens must be at least twin size unless the largest size made is smaller. A mattress sold with a foundation is tested with it, and is a separate prototype from the same mattress sold alone.
Test conditions (section 1633.7). Specimens are conditioned between 18 °C (65 °F) and 25 °C (77 °F) at under 55 percent relative humidity for at least 48 continuous hours. One burner flames the top surface for 70 seconds; the other flames the side of the mattress and foundation for 50 seconds.
Who counts as manufacturer. For part 1633, “importers and renovators are considered manufacturers.” A manufacturer may build to another firm’s qualified prototype under a pooling arrangement, but must run a confirmation test on at least one specimen of its own production first (section 1633.5). Section 1633.6 also requires a quality assurance program, including incoming inspection of materials.
Exemptions. Physician-prescribed “one of a kind” mattress sets are exempt from testing if they carry a specific warning label (section 1633.13(c)). CPSC’s page adds FDA-registered medical device mattress sets, calling this “a very narrow exemption that applies only if the mattress set is a medical device registered with the FDA.” Medical claims alone do not qualify.
Futons, Sofa Beds and Crib Mattresses
For futons and sofa beds, CPSC’s page says that if the mattress portion is detachable, the detached mattress is “likely only subject to” parts 1632 and 1633, and the rest of the product is “likely subject to 16 C.F.R. part 1640,” the upholstered furniture standard. If the mattress is permanently attached, “the product as a whole is likely subject to 16 C.F.R. part 1640.”
Crib mattresses carry extra rules: “Crib mattresses are also subject to 16 C.F.R. part 1241 and 16 C.F.R. part 1130.” Our infant sleep products guide covers the infant sleep rules; this guide does not summarize part 1241.
Labels: Part 1632 vs Part 1633
Part 1632 label (section 1632.31(b)). Each mattress or mattress pad must bear “a permanent, accessible, and legible label containing the month and year of manufacture and the location of the manufacturer.” Pads with a chemical fire retardant must also carry the letter “T” and permanent care instructions protecting their flame resistance.
Part 1633 label (section 1633.12). Each mattress set needs a permanent, conspicuous and legible label in English, with “the following information (and no other information)”:
| # | Element |
|---|---|
| 1 | Manufacturer name; for imports, the foreign manufacturer and importer |
| 2 | Complete physical address; for imports, the foreign manufacturer’s address with country, and the US importer or records location |
| 3 | Month and year of manufacture |
| 4 | Model identification |
| 5 | Prototype identification number |
| 6 | Certification statement citing 16 CFR part 1633 |
| 7 | Statement of whether the mattress is intended for use with or without a foundation |
The certification and use statements have fixed wording in section 1633.12(a)(6) and (a)(7). The label is 2¾ inches wide, black on white, in 6-point type or larger.
Records: The 3-Year Rule
Both parts require a prototype file that outlives production.
| Part 1632 (section 1632.31(c)) | Part 1633 (section 1633.11) | |
|---|---|---|
| Who keeps it | Manufacturer, importer or other first introducer | Manufacturer, including importers |
| Core contents | Prototype specs and ID, certified cigarette test results, photographs of each tested surface, ticking class or supplier certification, substitution evidence | All test results including failures, test video or at least eight photographs, prototype specs, quality assurance and production lot records |
| How long | While the prototype is in production, and 3 years after | While sets on the prototype are in production, and 3 years after |
| Where | Not specified | US plant, or for imports a US location named on the label |
Records “shall be available upon the request of Commission staff” (section 1633.11).
Which Certificate to Issue: GCC or CPC
CPSC’s page says general-use mattresses, mattress pads and mattress sets require a General Certificate of Conformity, issued “based on testing or a reasonable testing program.” Neither CPSC’s page nor the two regulations define “reasonable testing program” for mattresses; both parts say tests for a Flammable Fabrics Act guaranty are the required prototype tests.
| General-use mattress | Children’s mattress (e.g., crib mattress) | |
|---|---|---|
| Certificate | GCC | CPC |
| Rules to cite | Parts 1632 and 1633 (pads: 1632) | Parts 1632 and 1633, plus 1241 and 1130 for crib mattresses |
| Testing | Testing or a reasonable testing program | A third-party, CPSC-accepted laboratory |
For certificate elements, see our Children’s Product Certificate guide. Importers now eFile certificate data at entry; see our CPSC eFiling guide.
What This Means for an Amazon Listing
Before listing, the working file is a scope decision, passing prototype results, labels matching sections 1632.31 and 1633.12, the records file, and a GCC or CPC. Amazon’s document requests are in our Manage Your Compliance guide. For a product that fails, see our Section 15(b) guide and Amazon product recalls guide.
Common Mistakes
- Testing only to part 1632. Mattresses need both standards; only pads stop at part 1632.
- Reusing a “with foundation” prototype for a mattress sold alone. Part 1633 treats them as separate prototypes.
- Assuming a supplier’s results transfer. A pooled prototype still needs a confirmation test (section 1633.5).
- Adding marketing text to the 1633 label. It allows the seven elements “and no other information.”
- Calling a mattress “medical” to exit part 1633. CPSC says medical claims do not remove a set from scope.
Pre-Listing Checklist
- Classify the item against sections 1632.1 and 1633.2: mattress, mattress pad, mattress set, topper, or excluded.
- For futons and sofa beds, decide whether the mattress is detachable.
- Hold passing part 1632 prototype results (and part 1633 results for mattresses).
- Check the 1632 label and the seven-element 1633 label.
- Confirm records will be kept for production plus 3 years, at a US location for imports.
- Issue a GCC, or a CPC with third-party lab testing for crib and other children’s mattresses.
Frequently Asked Questions
Does 16 CFR 1633 apply to mattress toppers?
No. Section 1633.2(a)(2) excludes mattress toppers and mattress pads from the part 1633 definition of mattress. Part 1632 does not mention toppers, so check a topper against the part 1632 mattress pad definition (data checked 2026-10-13).
Do futon mattresses have to meet the mattress flammability standards?
Futons are named in the mattress definitions of both part 1632 and part 1633. CPSC’s guidance says a futon with a permanently attached mattress is likely subject to part 1640 as a whole.
Who has to do the 16 CFR 1633 test when I import mattresses?
Part 1633 treats importers as manufacturers, so the importer must hold qualification or confirmation test records at a US location named on the label.
Is a roll-packed mattress sold without a box spring a mattress set?
Yes. Section 1633.2(c) defines a mattress set to include “a mattress labeled by the manufacturer for sale without any foundation.”
Conclusion
Mattress flammability compliance means passing the part 1632 and part 1633 tests, permanent labels, records kept 3 years past production, and a GCC or CPC citing the parts that apply.