Certificate to Sell Kids Tools in USA

Countries around the world place great importance on children’s safety and health, with particULarly strict safety inspection standards for children’s products. This guide introduces the compliance requirements for such products.

When discussing compliance for children’s products, we often encounter these acronyms: CPSC, cpsia, CPC, ASTM. What do they mean?

Key Organizations and Regulations

1. CPSC (Consumer Product Safety Commission)

A federal agency that regulates children’s products to ensure consumer product safety.

2. CPSIA (Consumer Product Safety Improvement Act)

A law establishing product quality standards. All products coveRED by CPSIA must have a CPC.

3. CPC (Children’s Product Certificate)

A certificate issued based on testing data from a CPSC-accredited third-party laboratory to confirm compliance with regulations.

4. ASTM (American Society for Testing and Materials)

An organization that develops U.S. consumer product standards.

Definition of “Children’s Products” in the U.S.

Consumer products intended for children 12 years old and under, including plush/plastic/wooden toys, children’s clothing, baby products, children’s furniture/accessories, toy vehicles, and more.

CPC Certificate

①　A CPC certifies that the product complies with all CPSCand ASTM F963safety requirements.

②　The product must indicate the minimum applicable age.

③　Any product intended for children under 12 must have a CPC before being sold in the U.S.

④　Sellers must prepare a CPC for each product, shipped together with the goods.

A CPC includes:

①　Manufacturer/importer name

②　Export country

③　Contact information & address

④　Applicable ASTM standards list

⑤　Product name, material, color, SKU

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

New CPCs are required when:

①　Exporting a product for the first time

②　Exporting new versions (color, design, or material changes)

③　Changing suppliers or production facilities

④　Retesting products

Additionally, products must comply with lead and phthalate (plasticizer) content limits as specified by ASTM, verified by CPSC-approved third-party lab testing.

Labeling Requirements for Children’s Products

1. CPSIA Tracking Label

①　All children’s products must have a permanently affixed tracking label.

②　Must include: manufacturer name, U.S. address, U.S. phone number, production date, production location, batch number.

③　Purpose: to ensure effective recalls by identifying affected products.

④　Details: https://www.cpsc.gov/Business--Manufacturing/Business-Education/tracking-label

2. Consumer Registration Cards

①　Required for durable infant/toddler products (cribs, bassinets, play yards, etc.).

②　Must be included with each product to enhance recall effectiveness.

Registration cards must include:

①　Manufacturer name

②　Contact information

③　Product name/model

④　Production date

⑤　Backend product info must match documentation.

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

3. Suffocation Warning Labels (Plastic Bags)

Amazon requires suffocation warnings for any plastic/shrink bag with an opening ≥ 5 inches (≈12.7 cm), roughly the size of an infant’s head.

Example (Amazon sample 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 (ASTM F963)

①　Water toys:

WARNING: This is not a lifesaving device. Do not leave children unattended while in use.

②　Small parts:

WARNING: Choking hazard – small parts. Not for children under 3 years.

③　Balloons:

WARNING: Choking hazard – Children under 8 can choke or suffocate on uninflated or broken balloons. Adult supervision required. Keep uninflated balloons away from children. Discard broken balloons immediately.

Additional Federal Requirements

1. FHSA (Federal Hazardous Substances Act):Requires labels on children’s products containing hazardous substances (danger, warning, first aid, etc.).

2. LHAMA (Labeling of Hazardous Art Materials Act):Applies to art-related products (ceraMICs, clay, chalk, colored pencils, crayons, glue, jewelry kits, markers, paints, polymer clay, watercolor sets, stickers, etc.). Labels must include hazard warnings, ingredient names, safe handling instructions, and sensitive ingredient lists.

3. PPPA (Poison Prevention Packaging Act):Certain chemicals, cosmetics, ethanol-containing mouthwashes, drugs, and supplements must use child-resistant packaging (difficult for children under 5 to open, but accessible to adults/elderly).

4. FCC (47 CFR Part 15):Toys with remote controls and batteries must comply with FCC requirements.

5. DOT (U.S. Department of Transportation):Child car seats must comply with DOT standards.

6. ASTM F1816-97 & FFA (Flammable Fabrics Act):Flammability standards for children’s sleepwear and mattresses (16 CFR Parts 1615 & 1616).

7. FTC (Federal Trade Commission) 16 CFR Part 24:Leather and imitation leather product labeling requirements, including children’s leather goods.

Amazon’s Review Process for Children’s Products

Amazon reviews lab test reports, certificates, product photos, invoices, and more. They may request additional testing documentation at any time.

①　Non-compliant products will be removed, and accounts may be suspended.

②　Sellers must hold testing reports corresponding to ASTM and CPSC Standards.

③　Reports must be issued by CPSC-approved third-party labs; otherwise, CPC certificates are invalid.

Check lab list here: https://www.cpsc.gov/cgi-bin/labsearch/SearchResult.aspx?ReqId=VvOKqmsMe6czUqpa6fYwCA%3d%3d

Useful References

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

Children’s Products: https://www.cpsc.gov/Business--Manufacturing/Business-Education/childrens-products

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

Federal Regulations:

https://www.ecfr.gov/current/title-161000

Important Reminder: Infringement Risks

①　Toys account for a large portion of infringing products.

②　Without authorization documents, customs will destroy goods upon inspection.

③　To avoid losses, sellers must:

a.        Prepare compliance certificates and product labels before shipment

b.       Check product appearance, packaging, store titles, and descriptions for infringement risks