It depends on whether the product requires certification and whether relevant apparel enforcement discretion applies. “All clothing needs a new certificate” is too broad. CPSC’s general eFiling implementation began July 8, 2026, but its guidance continues to distinguish products requiring certificates from other cases. (cpsc.gov)
For clothing flammability, CPSC identifies testing exemptions including:
- Plain-surface fabrics weighing at least 88.2 grams per square meter.
- Fabrics made entirely from specified fibers, including wool, or combinations of those listed fibers, regardless of weight. (cpsc.gov)
Separately, CPSC states that it exercises certification enforcement discretion for adult apparel exempt from testing under 16 CFR 1610.1(d). Testing exemption, certification treatment and exclusion from the safety standard are not interchangeable concepts. (cpsc.gov)
What should the buyer ask the supplier?
Please confirm whether this garment requires CPSC certification and eFiling. If you rely on adult-apparel enforcement discretion, identify the basis and confirm that your carrier or broker can handle the appropriate disclaimer.
Request evidence for the finished garment, rather than accepting “wool” as a complete compliance answer. Have the supplier assess relevant components and materials instead of inferring the status of the whole suit from the shell-cloth description.
Buying for personal use does not by itself turn an ordinary seller-to-consumer shipment into a noncommercial transfer. CPSC distinguishes commercial transactions from gifts and transfers of personal effects. (cpsc.gov)
For operational instructions, use the current document library: it lists September 30, 2026 updates to filing guidance and an August 31, 2026 mail-shipment guidance document. Those are implementation resources—not new guarantees about delivery time or garment quality. (cpsc.gov)