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United States · Global Market Access

Entering the US Market: Children's Products (CPSIA)

Lead, phthalate and third-party testing requirements for children's products.

Market
United States
Site
North America
Mark
CPSIA

01What is it?

The CPSIA sets limits for substances such as lead and phthalates in children's products and requires testing in an accredited third-party laboratory. A Children's Product Certificate (CPC) is issued as a result.

02Why Does This Scheme Exist?

The present strictness of the consumer product safety arrangement in the United States is the consequence of a series of recall events. In 2007, high lead content in children's toys and injuries caused by swallowable magnets led to large-scale recalls and showed that the existing arrangement fell short for children's products.

The legislative response brought three structural changes. The first was setting strict content limits for lead and phthalates in children's products. The second was making the use of a THIRD-PARTY LABORATORY mandatory for children's products: a manufacturer cannot submit its own testing as evidence; a report from a laboratory accepted by the commission is required.

The third change is the CHILDREN'S PRODUCT CERTIFICATE: a document declaring the product's conformity and showing to which standards and in which laboratory it was tested is kept ready for every shipment and produced on request. This document is not an authority approval; it is the importer's or manufacturer's documented declaration.

The second distinguishing instrument of the arrangement is the TRACKING LABEL: for children's products, manufacturer details, place and date of manufacture and batch information must be permanently present on the product. The aim is to make recalls targeted; for a product without batch information, a recall extends to the whole stock.

The age declaration is a technical decision under this arrangement, not a marketing preference: it determines whether the product counts as a children's product and which set of requirements it falls under. State-level chemical warning obligations also sit on top of the federal layer and federal conformity does not satisfy them.

03Whose Obligation?

The obligation lies with the importer or domestic manufacturer: that party issues the CPC and produces it on request.

04Required Documents

  • Test reports from an accredited (CPSC-accepted) laboratory
  • The Children's Product Certificate (CPC)
  • Tracking label details
  • Product component and material list
  • Production batch and date details

05Process

  1. 01Scope DeterminationIt is determined which legislation and marking scope the product falls under in the target market. This step defines the entire process; getting it wrong wastes all subsequent work.
  2. 02Determining Applicable StandardsThe standards accepted by the market and any national deviations are identified. The same IEC standard may apply with different deviations in different markets.
  3. 03Establishing the Test PlanIt is assessed which part of existing test reports will be accepted; missing tests are planned. A CB Scheme report, if available, reduces retesting.
  4. 04Local Party and RegistrationIf the market requires an established representative, importer or applicant, this party is designated and the necessary registrations are made.
  5. 05Tests and Technical FileTests are conducted and the technical file is prepared. Some markets require testing to be performed within their own country.
  6. 06Certification or DeclarationDepending on the market's regime, a manufacturer's declaration is drawn up or a certificate is obtained from the authorised body; a factory audit is carried out if required.
  7. 07Marking and LabellingThe mark and label are applied according to the market's format and language rules. The language requirement is checked at customs in most markets.
  8. 08Shipment and CustomsIf a pre-shipment document is required, it is obtained; the document set to be presented at customs is completed.

06Points to Watch

  • Testing must be carried out in a laboratory accepted by the CPSC
  • The tracking label is mandatory on the product and the packaging
  • Small parts and choking hazard requirements apply in addition
  • The ASTM F963 toy standard is a mandatory consumer product safety standard

07Neighbouring Schemes and the Difference

  1. 01The US children's product arrangement and EU toy legislationBoth carry chemical and mechanical requirements but the thresholds, test standards and forms of evidence differ. Testing carried out for the EU does not satisfy the third-party certification requirement.
  2. 02The children's product certificate and the general conformity certificateFor children's products a third-party laboratory is mandatory; for adult consumer products a general certificate of conformity may suffice and the manufacturer can rely on its own testing.
  3. 03The toy standard and product-specific standardsAlongside the general toy safety standard there are separate mandatory standards for items such as infant products, bicycles, beds and furniture; the general standard does not cover them.
  4. 04Federal conformity and state obligationsCertain states' chemical warning requirements and substance bans are independent of the federal layer; a product that is federally compliant may not be fit for sale in some states.

08Scheme Detail

There is no separate certification page for this mark; the scope and process are as described on this page. The roadmap specific to your product is provided in writing at the quote stage.

09Other Marks in the United States Market

10Frequently Asked Questions

This section's content is being prepared. The roadmap specific to your product and target market at the quote stage in writing.

The certification timeline varies with the product, the required test workload, sample shipping time and the authority's workload; for this reason, no duration in days or weeks is given on these pages. The main factors determining the timeline are: whether testing must be performed in the target country, whether a factory audit is required, the time to appoint a local representative, and the current maturity of the technical file. A realistic timeline for your product is provided in writing at the quote stage.

Market access regimes change frequently: scope lists are updated, transition periods are extended, new requirements are added. These pages describe the structure of the regime and who bears the obligation; the applicable scope and dates for your product are confirmed from the current legislative text at the quote stage.

United States · CPSIA roadmap for

Tell us about your product; we'll share the required steps, documents and timeline in writing.

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