Hotel Mattresses for US Projects: 16 CFR 1632 and 1633, and the Duty Orders on Mattresses from China

A hotel mattress imported into the United States meets two separate federal flammability rules and may also fall under US duty orders on mattresses from China. The rules are in 16 CFR Part 1632 (cigarette ignition) and 16 CFR Part 1633 (open flame), and the duty orders are published by the US Department of Commerce. This guide reads the primary texts so a procurement team knows which questions to put to a mattress maker and to its customs broker.

It is a reading guide, not legal advice, and it covers US federal rules only. It was written from the eCFR text of Parts 1632 and 1633 (date of text 30 September 2026) and from three Federal Register notices read on 5 October 2026. Rules and orders change, so confirm the current text and status before you order, and do not treat any maker’s statement as proof that a product meets either part.

What does 16 CFR Part 1632 test?

Part 1632 is titled “Standard for the Flammability of Mattresses and Mattress Pads.” Its test criterion is that individual cigarette test locations pass if the char length is not more than 2 inches (5.1 cm) in any direction from the nearest point of the cigarette. The text also tells the test operator to discontinue the test and record a failure if an obvious ignition occurs before that char length is reached. Read the standard at the eCFR page for Part 1632.

The definition of “mattress” in 1632.1 includes adult, youth and crib mattresses, bunk bed mattresses, futons, and detachable mattresses used in upholstered furniture such as convertible sofa bed mattresses and trundle bed mattresses. It excludes pillows, mattress foundations, and upholstered furniture that does not contain a detachable mattress, including sofa beds of the jackknife type. Whether a given hotel item is inside or outside the definition depends on its construction, so ask the maker to describe the item against the definition.

The applicability clause says the prototype-testing requirements apply to each manufacturer, and also to all other persons or firms initially introducing mattresses into commerce, including importers. In other words, importing the product makes the importer responsible for the same obligations as the maker.

What does 16 CFR Part 1633 test?

Part 1633 is the open-flame standard for mattress sets. Its stated purpose is to reduce deaths and injuries associated with mattress fires by limiting the size of the fire generated by a mattress set during a thirty minute test. The text sets two criteria that a specimen must meet: the peak rate of heat release must not exceed 200 kilowatts at any time within the 30 minute test, and the total heat release must not exceed 15 megajoules in the first 10 minutes. Read the standard at the eCFR page for Part 1633.

Two definitions matter for hotel purchasing. A “mattress set” is either a mattress and foundation labeled by the manufacturer for sale as a set, or a mattress labeled for sale without any foundation. The text also says a mattress sold with a foundation is tested with that foundation. If you buy a mattress and a base from different makers, ask who has qualified that combination, because the labeled set is the unit the standard addresses.

Section 1633.1 says all mattress sets manufactured, imported or renovated on or after the effective date are subject to the standard. Section 1633.2 defines “manufacturer” as an individual plant or factory at which mattress sets are manufactured or assembled and adds that, for purposes of Part 1633, importers and renovators are considered manufacturers.

Who holds the records and what goes on the label?

Part 1633 requires every manufacturer, and any other person initially introducing mattress sets into commerce, to maintain test and manufacturing records in English at a location in the United States. For mattress sets produced outside the United States, the text says a copy of all required records must be maintained at a U.S. location, which must be identified on the mattress set label.

The labeling section requires a permanent, conspicuous and legible label in English. For imported mattress sets, the label must show the name of the foreign manufacturer and the importer, the complete address of the foreign manufacturer including country, and the complete address of the importer or the US location where the records are kept. The label must also show the month and year of manufacture, the model identification, the prototype identification number and a certification statement that refers to 16 CFR part 1633, in one of the forms the text sets for mattresses sold with or without a foundation.

For a project buyer, this turns into practical questions. Who will be the importer of record named on the label? Where in the United States will the records be kept? Has the maker qualified a prototype for the exact mattress and foundation combination you are buying, and will it hand over the test records you need? Put these questions in the enquiry. Part 1633 also requires each manufacturer to run a quality assurance program so that production matches the qualified prototype in materials, components, design and methods of assembly, so ask how the maker controls that on the production line.

Do the US duty orders on mattresses from China apply?

Separately from flammability, the US Department of Commerce has duty orders on mattresses from China. Commerce published the antidumping duty order (case A-570-092) on 16 December 2019, and published a continuation of that order on 28 May 2025, applicable from 20 May 2025, after a sunset review. Read the 2019 order and the 2025 continuation notice.

The scope in the continuation notice covers all types of youth and adult mattresses, defined by nominal width, length and depth, including innerspring, non-innerspring and hybrid mattresses. It says covered mattresses may be imported independently, as part of furniture or furniture mechanisms, or as part of a set with a foundation, and that only the mattress is covered if imported with a foundation or furniture. It excludes futon mattresses, airbeds and waterbeds, and certain multifunctional furniture convertible from seating to sleeping where the filling is integrated into and inseparable from the furniture framing. The notice lists Harmonized Tariff Schedule subheadings but states that the written description of the merchandise is dispositive.

There is also a countervailing duty order on mattresses from China (case C-570-128), published in May 2021. On 24 July 2026 Commerce published the final results of the expedited first sunset review of that order, finding that revocation would be likely to lead to continuation or recurrence of countervailable subsidies. Read the July 2026 notice. The notice sets rates by producer and exporter, and the rates and any further steps can change, so ask your customs broker for the current rate that applies to the specific producer and product before pricing.

Which duties apply to your shipment depends on the product description, the producer and exporter, and the country of origin, so this guide does not calculate any duty. It only flags that a hotel mattress from China needs to be checked against the scope text of both orders. For the wider US duty picture, see our guide to the US import duty structure for furniture and building materials and our note on the US antidumping order on wooden bedroom furniture, which is a different order.

What to put in a hotel mattress enquiry for a US project

• Mattress and foundation: state whether you buy mattresses only or labeled sets with foundations, and name the foundation if one is to be qualified with the mattress.
• Importer of record and record location: who will be named on the label and where the US records will be kept.
• Prototype evidence: ask for the prototype identification number and the test records for the exact construction offered, to the extent the maker may share them.
• Quality assurance: ask how production is controlled against the qualified prototype.
• Product description for customs: give your customs broker the construction and size so the scope of both duty orders can be checked against the written description.
• Cigarette and open-flame requirements: name both Part 1632 and Part 1633 in the specification, so the quotation covers both.
• Hotel brand standards: if the hotel brand sets mattress standards of its own, state them separately from the federal rules.

Next steps for a hotel mattress package

Send each maker the same brief, including the points above, and ask for answers in writing. For the supply side of mattresses and bedding, see our hotel mattress and bedding guide. For upholstered seating that has a separate US label rule, see our guide to the federal SOFFA label under 16 CFR 1640. FBM Sourcing also runs FBM Furniture’s hotel guestroom furniture pages for furniture-only packages.

Questions buyers ask about US mattress rules and Chinese hotel mattresses

Do hotel mattresses need to meet 16 CFR 1633?

Part 1633 applies to mattress sets manufactured, imported or renovated after its effective date, and defines importers as manufacturers for purposes of the part. Read the current text and ask the maker for the prototype records for the exact construction.

What is the difference between 16 CFR 1632 and 1633?

Part 1632 is the cigarette ignition standard for mattresses and mattress pads. Part 1633 is the open-flame standard for mattress sets, with limits on peak heat release and total heat release.

Does an importer take on the maker’s obligations?

Both parts treat importers as manufacturers for their requirements, so an importer should ask for the test records, name the US record location, and check the label content before shipment.

Does the antidumping order cover every mattress from China?

The scope text is the test, not the product name. It covers adult and youth mattresses as defined and excludes items such as futon mattresses, airbeds, waterbeds and certain integrated convertible furniture. Check your product description against the written scope with your customs broker.

How does FBM Sourcing support a hotel mattress order?

We review the brief, collect comparable quotations and manage the package for the project. For suppliers you nominate, we charge a 5% commission; for products we source for you, we quote a direct price. Our own team performs one inspection after bulk production is complete and before shipment, and the client’s project team is welcome to attend.

FBM Sourcing manages the entire China procurement package for overseas construction projects. We work with Developers · General Contractors · Builders · Commercial Project Owners · Interior Design & Construction Companies · FF&E Solution Providers.