US children's products (CPSIA): lab testing, CPC, tracking labels, lead limits

Testing and the Children's Product Certificate

Manufacturers should first determine the intended age of a product's users. If a product is designed or intended primarily for children 12 years of age or younger, the US manufacturer or, for products made abroad, the importer must certify it in a Children's Product Certificate based on passing test results from a CPSC-accepted third-party laboratory. The certificate covers every applicable rule, such as lead, phthalates, small parts and product-specific standards. CPSC certificate data must also be filed electronically with the import entry; see Triplicate's note on CPSC eFiling.

Children's products with more than 100 ppm lead in an accessible component are banned hazardous substances, and paint and surface coatings are limited to 90 ppm. Some untreated materials and certain untreated engineered wood products are exempt from lead testing, but they still have to meet the lead limit. Durable infant or toddler products, such as cribs, strollers, baby carriers and high chairs, also need a product registration card.

What the tracking label must show

• The name of the manufacturer or private labeler (for imports, the importer's name should be on the label)
• The location of production
• The date of production
• Batch or run number, or other details of the manufacturing process
• Any other information that helps identify the specific source of the product
• Marked permanently on the product and its packaging; on the shipping carton if marking the product is not practicable

Phthalates and small parts

Children's toys and child care articles must not contain more than 0.1 percent of any of 8 phthalates: DEHP, DBP, BBP, DINP, DIBP, DPENP, DHEXP and DCHP. The limit applies to any plasticized component part and to other component parts made of materials that may contain phthalates.

Products containing small parts are banned for children under 3 years old, and warning labels apply to products for children from 3 to under 6 years old that contain small parts. Exporters of toys, children's clothing, school supplies and similar goods should agree with their US importer which tests are needed and who issues the CPC before production starts.