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1. Understand the basic definition.
Any product designed or intended primarily for children 12 years of age or younger is a "children's product" under CPSC rules. This includes toys, baby strollers, cribs, children's furniture, high chairs, walkers, clothing, and childcare articles.
2. The Children's Product Certificate (CPC) is non-negotiable.
Every children's product must be certified with a written CPC. The CPC is issued by the U.S. importer (for products manufactured overseas), not by the overseas factory. The certificate must be based on passing test results from a third-party laboratory accepted by the CPSC.
The CPC must include seven required elements and cite all applicable children's product safety rules. Both the CPC and supporting test reports must be in English. There is no mandated template, but all required information must be present and accurate.
3. Third-party testing is mandatory.
Federal law requires that every children's product be tested by a CPSC-accepted laboratory. The CPSC has accepted over 600 laboratories worldwide. The specific tests depend on the product type, materials, intended age, and use patterns.
A single product may require multiple tests across different regulations. Not all labs are accredited for all tests, so you may need to use more than one. Component part testing is allowed for certain requirements, which can reduce costs.
If you make material changes to a product after initial certification, you must retest the affected parts and issue a new CPC.
4. Be aware of the key safety rules.
The main regulations include:
CPSIA – Limits total lead content to 100 ppm for substrates and 90 ppm for paint/surface coatings. Also restricts eight specified phthalates to 0.1% each in children's toys and childcare articles.
ASTM F963 – The mandatory toy safety standard covering physical, mechanical, flammability, and toxicology requirements. Your CPC must cite the specific ASTM sections applicable to your product, not just "16 CFR part 1250".
16 CFR Part 1307 – Prohibits children's toys and childcare articles containing specified phthalates.
Also watch for product-specific standards. For example, infant swings and cradle swings must comply with ASTM F2088-25 starting July 25, 2026; old test reports based on F2088-24 will no longer be accepted.
5. Electronic filing (eFiling) is now required.
Starting July 8, 2026, importers must electronically file certificate data with U.S. Customs and Border Protection (CBP) via the ACE system at the time of entry. This is not a new certification requirement – products that need a CPC still need one – but the data must now be submitted electronically and in real time.
If certificate data is missing, incomplete, or incorrect, shipments can be delayed, flagged, or denied entry. Any mismatch between the physical product, the certificate, and the eFiled data can trigger an audit and additional costs.
6. Tracking labels are required on all children's products.
Every children's product and its packaging must bear permanent tracking information. The label must include the manufacturer or private labeler name, production date, and location. The mark must be durable enough to last through the product's expected lifespan.
7. Durable infant and toddler products have extra requirements.
Beyond the CPC and tracking label, durable infant and toddler products must be permanently marked with the manufacturer's name, U.S. contact information, model name/number, and date of manufacture on both the product and packaging.
You must also provide a postage-paid product registration card attached to each product. This allows manufacturers to contact consumers in case of recalls.
8. Warning labels apply to specific products.
Certain products require specific warning labels. For example, toys with small parts intended for children ages 3 to 6 must carry choking hazard warnings on both the product and packaging. Aquatic toys like neck floats have specific labeling requirements. Always check whether your product category has additional warning label mandates.
9. Know who is responsible.
The U.S. importer of record is legally responsible for issuing the CPC, even if a lab or third party helps draft it. The importer cannot simply pass along a foreign manufacturer's CPC. However, the importer does not need to be physically located in the U.S. or list a U.S. address on the CPC.
10. Stay current with standard updates.
The CPSC periodically updates mandatory rules or publishes new ones. Standards like ASTM F963 are revised regularly, and CPSC may issue final rules that go beyond the ASTM requirements – as seen with the recent water bead toys rule. Always check the latest version of applicable standards before testing and certification.
11. Don't overlook state-level requirements.
Some states have additional restrictions. California Proposition 65 restricts lead, phthalates, and other substances in children's products sold in California. Connecticut requires PFAS labeling on certain products starting July 1, 2026. These are in addition to federal requirements.
12. Use the available tools.
The CPSC offers a Regulatory Robot tool that walks you through questions to identify which regulations apply to your product. There is also a searchable database of CPSC-accepted laboratories. Use these resources early in your product development process.