CPSIA Compliance for Children's Products

Countries worldwide place great emphasis on children's safety and health, enforcing strict safety standards for children's products. Today, let's discuss the compliance requirements for these products.

When it comes to children's product compliance, we often see the following abbreviations: CPSC, CPSIA, CPC, and ASTM. What do they mean?

Key Regulatory Terms

1. CPSC (Consumer Product Safety Commission)

The Consumer Product Safety Commission is a federal agency responsible for regulating children's products.

2. CPSIA (The Consumer Product Safety Improvement Act)

The Consumer Product Safety Improvement Act establishes product quality standards. All products covered under CPSIA must have a CPC.

3. CPC (Children's Product Certificate)

A Children's Product Certificate is issued based on testing data by a third-party laboratory authorized by CPSC, confirming compliance with safety regulations.

4. ASTM (American Society for Testing and Materials)

The American Society for Testing and Materials is an organization that sets consumer product standards in the U.S.

Testing & Certification Requirements: CPC

Definition of "Children’s Products" in the U.S.

Products designed for children 12 years and under, including plush/plastic/wooden toys, children's clothing, baby products, children's furniture/accessories, toy cars, etc.

1. CPC Certificate

- The CPC certificate proves that a product meets all CPSC and ASTM F963 safety requirements.

- The product should indicate the minimum applicable age.

- All products intended for children under 12 years old require a CPC to be sold in the U.S.

- Sellers must prepare a CPC for each product and ship it with the goods.

The CPC must include:

- Manufacturer/Importer details

- Exporting country

- Contact information and address

- Applicable ASTM standards

- Product name, material, color, SKU

Sample CPC: www.cpsc.gov/Testing-Certification/Childrens-Product-Certificate-CPC

New CPC certificates are required when:

- Exporting for the first time

- Exporting a new product (e.g., new color, design, or material)

- Changing suppliers or production facilities

- Re-testing the product

2. Testing Requirements

- Lead and phthalate (plasticizer) content must meet ASTM safety standards.

- Products must be tested by a CPSC-authorized third-party laboratory.

Children's Product Labeling Requirements

1. CPSIA Tracking Label

- CPSIA mandates that all children's products have a permanently affixed tracking label.

- The label should include:

 - Manufacturer name

 - U.S. address and phone number

 - Production date

 - Production location

 - Batch number

Purpose: Ensures effective product recalls. If a component is found hazardous, tracking labels help identify other products that may contain the same component.

More details: www.cpsc.gov/Business--Manufacturing/Business-Education/tracking-label

2. Consumer Registration Cards

- Durable infant/toddler products (e.g., cribs, cradles, playpens) must include consumer registration cards to enhance recall effectiveness.

- These cards should include:

 - Manufacturer name

 - Contact information

 - Product name/model

 - Production date

More details: www.cpsc.gov/Business--Manufacturing/Business-Education/Durable-Infant-or-Toddler-Products/Durable-Infant-or-Toddler-Product-Consumer-Registration-Cards

3. Choking Hazard Warning Labels

Amazon requires suffocation warning labels on plastic bags ≥5 inches (12.7 cm) in diameter, as they pose a choking hazard.

Example Amazon Warning Text:

_Warning: To avoid the danger of suffocation, keep this plastic bag away from babies and children. Do not use this bag in cribs, beds, carriages, or playpens. This bag is not a toy._

4. Other Warning Labels

The U.S. toy safety standard ASTM F963 requires warning labels for certain toy categories:

- Water toys

[Warning] This is not a life-saving device. Do not use without adult supervision.

- Small parts

[Warning] Choking Hazard—Small parts. Not suitable for children under 3 years.

- Balloons

[Warning] Choking Hazard—Children under 8 years can choke on uninflated or broken balloons. Adult supervision required. Keep uninflated balloons away from children. Discard broken balloons immediately.

Additional Federal Requirements for Children's Products

1. Federal Hazardous Substances Act (FHSA)

- Requires warning labels on children's products containing hazardous substances.

2. Labeling of Hazardous Art Materials Act (LHAMA)

- Applies to art-related products such as:

 - Clay, chalk, colored pencils, crayons, glue, jewelry-making kits, markers, paints, polymer clay, stickers, etc.

- Labels must include:

 - Warnings

 - Names of hazardous ingredients

 - Safe handling instructions

3. Poison Prevention Packaging Act (PPPA)

- Requires child-resistant packaging for certain products, including:

 - Chemicals, cosmetics, ethanol-based oral rinses, medicines, and dietary supplements.

 - Packaging must be difficult for children under 5 years to open but easy for adults and the elderly.

4. FCC Compliance (Federal Communications Commission, 47 CFR Part 15)

- Toys with remote control or batteries must comply with FCC regulations.

5. DOT Certification (U.S. Department of Transportation)

- Child car seats must meet DOT requirements.

6. Flammability Standards (ASTM F1816-97 & Flammable Fabrics Act, 16 CFR Parts 1615 & 1616)

- Children’s sleepwear and mattresses must comply with flammability standards.

7. FTC (Federal Trade Commission) 16 CFR Part 24

- Children’s leather and faux leather products must comply with regulations.

Amazon's Review Process for Children's Products

Amazon reviews:

- Laboratory test reports

- Certificates

- Product photos

- Production invoices

Amazon can remove non-compliant products and suspend seller accounts for serious violations.

Sellers must provide valid test reports corresponding to listed ASTM and CPSC standards.

- Test reports must be issued by a CPSC-approved third-party laboratory.

- Otherwise, CPC certificates will be invalid.

Find CPSC-approved testing labs:

www.cpsc.gov/cgi-bin/labsearch/SearchResult.aspx?ReqId=VvOKqmsMe6czUqpa6fYwCA%3d%3d

More Resources on CPSIA and Children's Product Compliance

- CPSIA (Consumer Product Safety Improvement Act):

www.cpsc.gov/Regulations-Laws--Standards/Statutes/The-Consumer-Product-Safety-Improvement-Act

- Children’s Products Regulations:

www.cpsc.gov/Business--Manufacturing/Business-Education/childrens-products

- Children’s Product Certificate (CPC) Requirements:

www.cpsc.gov/Business--Manufacturing/Testing-Certification/Lab-Accreditation/Rules-Requiring-Third-Party-Testing

- U.S. Federal Regulations:

www.ecfr.gov/current/title-16#1000

Intellectual Property & Infringement Risks

- Toys are among the most frequently infringed products.

- Unauthorized products may be seized and destroyed by customs.

- Before shipping, ensure compliance by checking:

- Certificates & labels

- Product appearance & packaging

- Store listings & descriptions

By following these guidelines, sellers can avoid unnecessary losses and legal issues.