Safety of children's clothing - Recommendations for the design and manufacture of children's clothing - Mechanical safety

This Technical Report gives recommendations for the design and manufacture of safe children’s clothing in relation to mechanical hazards.
This Technical Report also gives recommendations on safety aspects of the packaging and display of children’s clothing, including guidance for retailers.
This Technical Report is applicable to clothing including bonnets, hats, gloves, scarves, socks and other clothing accessories intended for all children up to 14 years of age. It is suggested that dressing up clothes meet the recommendations of this Technical Report in addition to the requirements of EN 71.
This Technical Report is intended for use at all stages of the clothing supply chain, including use by designers, specifiers and manufacturers of children’s clothing. It is also intended to be used by importers, distributors and retailers to assist them in the selection of clothing that does not present a hazard.
This Technical Report is not applicable to:
a)   child care articles, such as bibs, nappies and soother holders;
b)   footwear, such as boots, shoes and slippers; or
c)   toys and other items sold with the clothing;
as these articles are not within the scope of CEN/TC 248.
This Technical Report does not include recommendations on any clothing features that might be necessary to cater for children with special needs.

Sicherheit von Kinderbekleidung - Empfehlungen für das Design und die Herstellung von Kinderbekleidung - Mechanische Sicherheit

Sécurité des vêtements d’enfants - Recommandations pour la conception et la fabrication des vêtements d’enfants - Sécurité mécanique

Varnost otroških oblačil - Priporočila za načrtovanje in izdelavo otroških oblačil - Mehanska varnost

To tehnično poročilo podaja priporočila za načrtovanje in izdelavo otroških oblačil v povezavi z mehansko varnostjo.
To tehnično poročilo podaja tudi priporočila o varnostnih vidikih embalaže in razstavljanja otroških oblačil, vključno s smernicami za trgovce.
To tehnično poročilo se uporablja za oblačila, vključno s klobuki, kapami, rokavicami, šali, nogavicami in drugimi dodatki za oblačila, ki so namenjeni vsem otrokom do 14 leta starosti. Priporočeno je, da oblačila poleg zahtev standarda EN 71 dosegajo priporočila v tem tehničnem poročilu.
To tehnično poročilo je namenjeno uporabi na vseh ravneh oskrbovalne verige z oblekami, vključno z oblikovalci, izdajatelji specifikacij in proizvajalci. Namenjeno je tudi za uporabo s strani uvoznikov, distributerjev in trgovcev, da jim pomaga pri izbiri oblačil, ki ne predstavljajo tveganja.
To tehnično poročilo se ne uporablja za:
a) izdelke za otroke, kot so slinčki, plenice in držala za dude;
b) obuvala, kot so škornji, čevlji in copati;
c) igrače in drugi predmeti, ki se prodajajo z oblačili,
saj ti predmeti niso zajeti v standardu CEN TC 248.
To tehnično poročilo ne vključuje nobenih priporočil glede lastnosti oblačil, ki so morda potrebne za skrb za otroke s posebnimi potrebami.

General Information

Status
Published
Publication Date
16-Dec-2014
Current Stage
6060 - Definitive text made available (DAV) - Publishing
Due Date
17-Dec-2014
Completion Date
17-Dec-2014

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SLOVENSKI STANDARD
SIST-TP CEN/TR 16792:2015
01-marec-2015

9DUQRVWRWURãNLKREODþLO3ULSRURþLOD]DQDþUWRYDQMHLQL]GHODYRRWURãNLKREODþLO

0HKDQVNDYDUQRVW

Safety of children's clothing - Recommendations for the design and manufacture of

children's clothing - Mechanical safety
Sicherheit von Kinderbekleidung - Teil 1: Mechanische Sicherheit
Sécurité des vêtements d’enfants - Recommandations pour la conception et la
fabrication des vêtements d’enfants - Sécurité mécanique
Ta slovenski standard je istoveten z: CEN/TR 16792:2014
ICS:
61.020 2EODþLOD Clothes
97.190 Otroška oprema Equipment for children
SIST-TP CEN/TR 16792:2015 en

2003-01.Slovenski inštitut za standardizacijo. Razmnoževanje celote ali delov tega standarda ni dovoljeno.

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SIST-TP CEN/TR 16792:2015
TECHNICAL REPORT
CEN/TR 16792
RAPPORT TECHNIQUE
TECHNISCHER BERICHT
December 2014
ICS 61.020; 97.190
English Version
Safety of children's clothing - Recommendations for the design
and manufacture of children's clothing - Mechanical safety

Sécurité des vêtements d'enfants - Recommandations pour Sicherheit von Kinderbekleidung - Teil 1: Mechanische

la conception et la fabrication des vêtements d'enfants - Sicherheit
Sécurité mécanique

This Technical Report was approved by CEN on 15 December 2014. It has been drawn up by the Technical Committee CEN/TC 248.

CEN members are the national standards bodies of Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia,

Finland, Former Yugoslav Republic of Macedonia, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Lithuania,

Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, Switzerland, Turkey and United

Kingdom.
EUROPEAN COMMITTEE FOR STANDARDIZATION
COMITÉ EUROPÉEN DE NORMALISATION
EUROPÄISCHES KOMITEE FÜR NORMUNG
CEN-CENELEC Management Centre: Avenue Marnix 17, B-1000 Brussels

© 2014 CEN All rights of exploitation in any form and by any means reserved Ref. No. CEN/TR 16792:2014 E

worldwide for CEN national Members.
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Contents Page

Foreword ..............................................................................................................................................................3

Introduction .........................................................................................................................................................4

1 Scope ......................................................................................................................................................5

2 Normative references ............................................................................................................................5

3 Terms and definitions ...........................................................................................................................6

4 Mechanical hazards and associated risks ..........................................................................................9

5 Risk assessment ................................................................................................................................. 10

6 Garment design, materials and construction .................................................................................. 11

7 Manufacture ......................................................................................................................................... 18

8 Packaging ............................................................................................................................................ 21

9 Security tagging and display of garments for retail........................................................................ 21

Annex A (informative) Accident data .............................................................................................................. 22

Annex B (normative) Method for determination of removal force of attached components .................. 23

Annex C (informative) Method for determination of the security of attachment of non-grippable

attached components ......................................................................................................................... 33

Annex D (informative) Information to be supplied by the designer to the manufacturer ......................... 37

Annex E (informative) Rational for age definitions ....................................................................................... 38

Annex F (informative) Test method for tensile strength of buttons and recommended minimum

strength. ............................................................................................................................................... 39

Annex G (normative) Slide/zip fastener specification .................................................................................. 42

Annex H (normative) Small parts assessment .............................................................................................. 43

Bibliography ..................................................................................................................................................... 44

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Foreword

This document (CEN/TR 16792:2014) has been prepared by Technical Committee CEN/TC 248, “Textiles and

textile products”, the secretariat of which is held by BSI.

Attention is drawn to the possibility that some of the elements of this document may be the subject of patent

rights. CEN [and/or CENELEC] shall not be held responsible for identifying any or all such patent rights.

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Introduction

The General Product Safety Directive 2001/95/EC [1] require all products placed on the market to be safe,

and provide information on how the safety of products should be assessed. According to the General Product

Safety Directive [1] product safety may be assessed by reference to the following:

— specific product regulations;
— national regulations;

— European standards which have had their references published in the Official Journal of the European

Union;
— other European standards;

— community technical specifications; national standards (i.e. national standards that are not versions of

European standards);
— industry codes of good practice; European Technical Report (TR)
— state of the art and technology; and
— the safety which consumers may reasonably expect.

More details on assessment of product safety are given in the EU The General Product Safety Directive

2001/95/EC.

When designing children’s clothing, it is essential to take into consideration the behaviour of children, whose

need for exploration and challenge drives them to use items in new and different ways. One common factor

children share is that they are unaware of cause and effect and are therefore substantially less cautious than

adults in relation to hazards.

It should be emphasized that consideration of the recommendations given in this Technical Report from the

earliest possible stage, i.e. the design stage, is of prime importance.

Recommendations on risk assessment are given in Clause 5. The recommendations given relate only to

mechanical safety. There are many other safety aspects relating to children’s clothing that need to be

considered when carrying out a full risk assessment, including chemical safety, thermal protection (against

heat or cold), avoidance of overheating, flammability,
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1 Scope

This Technical Report gives recommendations for the design and manufacture of safe children’s clothing in

relation to mechanical hazards.

This Technical Report also gives recommendations on safety aspects of the packaging and display of

children’s clothing, including guidance for retailers.

This Technical Report is applicable to clothing including bonnets, hats, gloves, scarves, socks and other

clothing accessories intended for all children up to 14 years of age. It is suggested that dressing up clothes

meet the recommendations of this Technical Report in addition to the requirements of EN 71.

This Technical Report is intended for use at all stages of the clothing supply chain, including use by designers,

specifiers and manufacturers of children’s clothing. It is also intended to be used by importers, distributors and

retailers to assist them in the selection of clothing that does not present a hazard.

This Technical Report is not applicable to:
a) child care articles, such as bibs, nappies and soother holders;
b) footwear, such as boots, shoes and slippers; or
c) toys and other items sold with the clothing;
as these articles are not within the scope of CEN/TC 248.

This Technical Report does not include recommendations on any clothing features that might be necessary to

cater for children with special needs.
2 Normative references

The following documents, in whole or in part, are normatively referenced in this document and are

indispensable for its application. For dated references, only the edition cited applies. For undated references,

the latest edition of the referenced document (including any amendments) applies.

BS 3084, Slide fasteners (zips) - Specification

EN 14682, Safety of children's clothing - Cords and drawstrings on children's clothing - Specifications

EN ISO 139, Textiles - Standard atmospheres for conditioning and testing (ISO 139)

EN ISO 3758, Textiles - Care labelling code using symbols (ISO 3758)

EN ISO 6330, Textiles - Domestic washing and drying procedures for textile testing (ISO 6330)

EN ISO 7500-1, Metallic materials - Verification of static uniaxial testing machines - Part 1:

Tension/compression testing machines - Verification and calibration of the force-measuring system (ISO

7500-1)

EN ISO 10012, Measurement management systems - Requirements for measurement processes and

measuring equipment (ISO 10012)
ISO 4915, Textiles - Stitch types - Classification and terminology
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3 Terms and definitions
For the purposes of this document, the following terms and definitions apply.
3.1
baby

child from birth up to age 12 months, that is all children of height up to and including 80 cm

3.2
infant

child from age 12 months to and including 36 months, that is all children over 80 cm and up to and including

98 cm in height
3.3
child and young person

person aged over 36 months and up to 14 years (that is up to and including 13 years and 11 months), that is

all children over 98 cm in height and for girls up to 176 cm and for boys 182 cm in height

3.4
babies' clothing
garments intended by design manufacture or selling route to be worn by babies
3.5
infant's clothing
garments intended by design, manufacture or selling route to be worn by infants
3.6
children’s clothing
garments intended by design, manufacture or selling route to be worn by children
3.7
foreign object
object not intended to be a part of a garment, for example, broken needle, stone
3.8
ischaemic injury
injury to a part of the body resulting from a restriction of blood circulation
3.9
attached components
3.9.1
press fastener

fastening device consisting of a male component and a female component that are attached to different parts

of a garment and which is fastened by aligning the two components and pressing them together

Note 1 to entry: Press fasteners include poppers and snaps.

Note 2 to entry: Press fasteners can be attached to a garment mechanically or can be sewn on.

3.9.2
tack button

fastening device comprising a button with a hollow shank on the back and a separate sharp tack, which is

attached to a garment by pushing the sharp end of the tack through the fabric from the reverse side into the

shank of the button
Note 1 to entry: Tack buttons are also known as stud buttons.
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Note 2 to entry: Tack buttons are widely used on denim and other casual garments.

3.9.3
rivet

two part assembly, comprising a part (referred to as a burr) which is attached to the outer surface of the

garment by a tack which passes though the fabric from the reverse side

Note 1 to entry: Rivets are usually used as reinforcements, particularly on the corners of pockets on denim and other

casual garments.
3.9.4
eyelet

item used to reinforce a hole through a garment, comprising a short metal tube with a flange at one end which

is fastened to the garment by pushing it through the hole and compressing it against a die

Note 1 to entry: An eyelet may also include a washer on the reverse side.

Note 2 to entry: Eyelets are used to facilitate lacing or the insertion of a drawstring, to drain pockets or to provide

ventilation.
3.9.5
pom-pom

ball created either from cut lengths of thread or yarn fastened at the centre, or from a piece of fabric filled with

filling material

Note 1 to entry: Pom-poms can be secured directly to a garment or attached by means of a cord.

3.9.6
tassel

bundle of lengths of yarn or other materials fastened at one end and free at the other end

Note 1 to entry: Tassels can be secured directly to a garment or attached by means of a cord.

3.9.7
tab

piece of textile or other material, of flat or looped construction, attached to the outside of a garment either for

identification or for decorative purposes

Note 1 to entry: These are distinct from adjusting tabs, which are defined in EN 14682.

3.9.8
button

knob or disc which is attached to a garment as a means of fastening or ornamentation

3.9.9
label

fabric, plastic or similar attached to the garment to provide instructions, information or to identify the garment

brand
3.10
garment assembly

section of a garment, made under production conditions, using production equipment and the components

that are to be used in production
3.11
hazard
potential source of harm to the wearer of a garment
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3.12
risk

combination of the probability of occurrence of a hazard and the severity of the harm which that hazard could

be expected to cause
3.13
risk assessment

thorough evaluation of the risks that a garment could present to the wearer as a result of the design,

materials, components and construction of the garment
3.14
sharp object

object with one or more edges or points which are exposed, or which could become exposed, and which are

likely to cause a cutting or piercing injury to the wearer of a garment
3.15
touch and close fastener

fastener consisting of two pile fabric tapes that are attached to different parts of a garment which is fastened

by pressing the pile sides of the two tapes together and which can be unfastened by peeling apart the two

tapes starting at either end
Note 1 to entry: Touch and close includes hook and loop.
3.16
wear trial

trial of a garment involving wear by intended users in order to obtain information on the wear performance and

characteristics of the garment
3.17
magnet

piece of iron, steel or alloy having the properties of attracting or repelling iron

3.18
magnetic material
material capable of being attracted by, or acquiring the properties of a magnet
3.19
zip/slide fastener

moving component consisting essentially of a slider body and, normally, a puller, which opens or closes the

fastener by separating or engaging the interlocking members

Note 1 to entry: The slider might incorporate a locking device. Alternative slider types are available with a flip-over

puller or double pullers, to facilitate operation from both front and back sides.

3.20
appliqué

cut out design or shape attached to the face of material for ornamentation, frequently of a different type and/or

shade of material
3.21
filling material
material which is encased in fabric to form part of the structure of a garment
Note 1 to entry: Filling materials include wadding, foams and feathers.
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4 Mechanical hazards and associated risks
4.1 Ischaemic injuries

Ischaemic injuries can be caused by loose or untrimmed threads on the foot or hand area of garments

becoming wrapped around fingers or toes, or by entrapment of fingers or toes in open fabrics (e.g. crochet) or

in fabrics with long float stitches. Entrapment of tongue or fingers is possible in large inflexible openings , in

components such as buttons, press fasteners, eyelets and zip/slide fasteners. These can cause a tourniquet

effect, thus restricting the blood circulation.

This is a particular concern in clothes for babies as the source of distress cannot be communicated by the

baby and might go undetected for some time.

In addition, areas of skin or parts of the genitalia can protrude through a mesh fabric used as a lining for

swimming trunks. The skin from these parts can become entrapped in the mesh leading to ischaemic injury.

Elasticated cuffs can also cause a reduction in blood flow to the hands or feet if the elastic is too tight or too

strong; this is a particular concern in baby clothing.
4.2 Entrapment of the penis in a slide fastener (zip)

All boys’ trousers that have a slide fastener present a risk of entrapment of the penis in the fastener.

4.3 Injuries from sharp objects

Injuries to children can be caused by clothing which contains sharp objects. The severity of the injury can

range from a scratch or irritation to a more serious injury such as cutting or piercing.

Injuries can be caused by components with sharp edges, which are sometimes found on buttons, slide

fasteners and decorative features, or by sharp edges which are produced through the deterioration of

components during the wear and aftercare lifecycle of the garment. For example, components of press

fasteners can become detached from the garment leaving sharp prongs exposed, and buttons can break, or

covered buttons can come apart, leaving a sharp edge.

Pins, broken needles, staples and other sharp objects used in the manufacture and packaging of clothing can

also cause serious injury if they are left in the garment.
4.4 Choking and aspiration

Buttons, toggles and many other garment attachments (including rubber and soft plastics items, such as

badges) can be a potential hazard, particularly to children under 36 months, if the item becomes detached

from the garment. As young children are known to place such items in their mouth, and might also insert them

into their nose or ears, any foreign object found in a child’s garment can present a risk of either choking or

aspiration. Stones left as a residue from a stone-washing process can present the same risks.

Aspiration (where items are inhaled via the mouth or nose) is possible if detached parts are sufficiently small

to pass into the trachea or lungs, for example beads, diamanté and sequins. Often these items might not be

detected, as their chemical nature means they are unlikely to be identified by X-ray. The consequence is the

foreign body can cause toxic shock or lead to an infection, the source of which might not be readily identified.

This can result in rapid and unexplained weight loss requiring hospitalization. This is very serious, however it

is extremely rare.
4.5 Swallowing

In most cases a detached item that has been swallowed will pass into the stomach and should eventually

pass through the body with food without causing harm. Notable exceptions are sharp objects, button cell

batteries and magnets.
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4.6 Magnets

If more than one magnet, or one magnet and a ferromagnetic object (for example iron or nickel) is ingested,

the objects can attract to each other across intestinal walls and cause perforation or blockage, which can be

fatal. Other risks include magnetic interference with devices such as pacemakers or infusion pumps.

4.7 Strangulation and entrapment

Garments manufactured with cords, drawstrings or loops present a potential risk of strangulation and,

entrapment. Studies of accident data indicate two distinct trends, see EN 14682:2014 Annex A .

4.8 Slipping, tripping and falling

Accident statistics show that the majority of tripping and falling accidents are caused by poorly fitting

garments. It is unclear whether this is due to inappropriate garment selection by the parent or carer or to the

garment itself being incorrectly sized. Examples of the latter could be a skirt or a trouser leg being too long in

relation to the waist and hip measurements. A belt or cord which is too long might also put the wearer at risk

of tripping. Some slipping accidents can be attributed to children of walking age wearing socks or footed

garments without wearing additional footwear.
4.9 Restriction of vision and hearing

Hoods and certain types of headwear can restrict a child’s vision or hearing, or both. Garments with hoods,

and certain types of headwear, have the potential to increase the risk of the child being involved in an

accident. Particular concern has been raised regarding an increased risk of playground and of road traffic

accidents.
4.10 Suffocation

Accident statistics suggest that suffocation accidents involving children’s clothing are rare. However, there

remains a risk of suffocation in babies under 12 months if a garment has a hood constructed from materials

which are impermeable to air.
5 Risk assessment

The General Product Safety Directive [1] specifies that all consumer products have to be safe or reasonably

safe in normal and foreseeable use.

Risk assessments should be carried out so as to cover every stage of the garment production process, from

the design stage, through manufacturing to retailing. This should include an exchange of information between

all those concerned with the design, manufacturing, buying and retailing of the garments to ensure that

garments put on sale to the public are safe.
The main stages that need to be carried out in a risk assessment are as follows:
a) identification of the hazards;
b) identification of the risks associated with each of the hazards;
c) removal of the hazards wherever possible;

d) for those hazards that cannot be removed, taking action to reduce the risks associated with them to an

acceptable level.

NOTE To assist in the assessment of risks associated with particular hazards, some recorded accident statistics are

given in Annex A.
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If a particular aspect of a garment design is found to present a risk, consideration should be given to removing

the feature and/or obtaining the same effect using a safer technique.

Measures to remove hazards and reduce risks at the manufacturing stage should include the following:

1) adapting to technical progress and using safer technology;

2) developing a coherent overall prevention policy which covers technology, organization of work, and

control of factors relating to the working environment, e.g. introducing a broken needle policy in a factory,

and control of hand sewing procedures and the use of pins and staples;

3) implementing manufacturing management procedures to avoid or minimize risk including giving

appropriate instructions to employees, for example on correct broken needle procedures.

Risk assessments should be done on all garments, covering the complete range of sizes.

The following factors should be taken into account:
— the age of the intended wearer;

— the expected characteristics of a child that age, and the situation in which they are likely to be wearing the

garment, including the following:
— weight and height of the child;

— body measurements relevant to specific potential hazards, e.g. wrist size in the case of a garment with

elasticated cuffs;
— the age-related abilities of the child;
— the normal behaviour of the child;
— the situation(s) in which the garment is intended to be worn;

— the normal levels of supervision of the child while they are wearing the garment. For example, not only is

a sleeping baby very unlikely to be supervised, but it might also continue to be unsupervised when it

wakes.

When carrying out a risk assessment, it should be borne in mind that young children up to around age 7 years

cannot be expected to appreciate risks and that their behaviour can be unpredictable.

Risk assessments should be documented. The documentation should be dated and identified so that it is

traceable, and should include a record of the name and position of the individual(s) who carried out the

assessment. Risk assessments should be reviewed at least annually for long-running styles and further action

taken to reduce risks if necessary.

Wear trials should never be carried out as part of a risk assessment to determine if a garment is safe. If a

previously unidentified safety issue, or perceived safety issue, becomes apparent during a wear trial then the

wear trial should be stopped immediately and the risk assessment should be reviewed.

6 Garment design, materials and construction
6.1 General

Assessed capability. Users of this Technical Report are advised to consider the desirability of sourcing

materials and components from suppliers who operate quality systems that have been assessed and

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registered against the appropriate standard in the EN ISO 9000 series by an accredited third-party certification

body.

Garment designs and sizing should be based on anthropometric data for children in the relevant age group.

The performance of materials and components can be greatly reduced by aftercare processes. It is important

therefore that the type and likely frequency of aftercare processes are taken into consideration when

assessing the materials and components in the garments. Appropriate care instructions should be provided

with each garment, for example see EN ISO 3758.

For each garment design, the designer should provide the manufacturer with a full product specification which

should include, as a minimum, the information listed in Annex D.
6.2 Selection of fabrics

6.2.1 Fabrics should be used which do not present a mechanical risk to the wearer when forming

part of a garment. If necessary, the construction of the garment should be altered so that the fabrics

used do not present a mechanical risk.

Particular consideration should be given to the position of the fabric on the garment, the age of the intended

wearer and the type of end use of the garment. Examples include:

a) In garments for babies, fabrics with integral holes or open construction, e.g. crochet and lace, which can

cause entrapment of fingers or other body parts leading to ischaemic injury (see 4.1) should not be used.

b) Mesh fabrics, which can present a risk of entrapment if used in the lining of boys’ swimming trunks (see

4.1). This risk can be reduced by using a soft handle fabric with a hole size less than 1,5 mm.

c) Imitation fur fabrics. A safety risk assessment should be carried out to assess, pile retention, position on

garment and age of end user (see 4.4).

6.2.2 Fabrics which have uncut float stitches longer than 10 mm should not be used in the hand or

foot area of garments designed for babies.

6.2.3 Fabric used to support a sewn-on component, for example a button, should be sufficiently

strong that when the attachment of the component is tested in accordance with Table 1 and 6.5.1,

Note 2, the fabric does not tear. If necessary, reinforcing material should be used in areas where

components are attached.
6.3 Filling materials

Filling materials should not contain any hard, sharp or foreign objects. Garments which contain filling material

should be designed and constructed in such a way that the filling material is inaccessible and secure.

Particular care should be taken when using feathers/down as a filling material, as the quills could present a

hazard to the wearer.
6.4 Sewing thread

Monofilament sewing thread should not be used on the inside of children’s clothing owing to the risk of it

causing ischaemic injury or skin abrasion.

All thread ends in the hand and foot areas of the garments for babies should be trimmed off to a maximum of

10 mm.

Thread used to support a sewn-on component, for example a button, should be sufficiently strong that the

security of attachment of the component is in accordance with Table 1 and 6.5.1, Note 2.

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6.5 Attached garment components
6.5.1 General recommendations

This sub-clause gives recommendations that apply to all attached garment components. Specific additional

recommendations for individual types of attached components are given in 6.5.2 to 6.5.9.

It is essential that all components attached to clothing for children under 36 months are securely attached and

remain attached throughout the normal or reasonably foreseeable period of use of the garment.

...

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