CPSIA Compliance for Children's Products

The U.S. Consumer Product Safety Improvement Act (CPSIA) mandates that importers and manufacturers of children's products (e.g., toys, cribs, and pacifiers) comply with relevant documentation, labeling, and testing requirements.

This document outlines the different categories of children's products covered by the CPSIA, examples of such products, and the applicable standards.

Please note that the CPSIA applies to all products designed for children aged 12 and under, not just those listed in this guide or subject to the specific safety rules referenced herein.

In each section below, we also list examples of safety standards relevant to the product categories covered. However, additional standards may apply.

Furthermore, certain standards or bans—such as 16 CFR Part 1303 or 15 U.S.C. § 1278a—regulate substance restrictions (e.g., lead) and are therefore applicable to multiple product categories. In the absence of specific safety rules or mandatory safety standards, companies are advised to adhere to relevant voluntary standards (e.g., ASTM standards).

1. Children's Toys

Toys intended for children aged 12 and under must meet CPSIA requirements, as unsafe toys can cause harm to children, leading to choking, burns, and poisoning. As such, toys must comply with the relevant ASTM safety standards and other requirements.

Examples

The CPSIA imposes safety requirements on the following toy categories:

①　Wooden toys

②　Plastic toys

③　Plush toys

④　Toy vehicles

Safety Standards

Examples of standards applicable to children's toys include:

a. 16 CFR Part 1250 – Toy Safety Standard: ASTM F963

b. 16 CFR Part 1505 – Requirements for Electric Toys and Other Electric Articles Intended for Use by Children

c. 16 CFR Part 1307 – Ban on Phthalates in Children's Toys and Child Care Articles

d. 16 CFR Part 1303 – Ban on Lead-Containing Paint and Certain Consumer Products Bearing Lead-Containing Paint

e. 16 CFR Part 1272 – Marking of Toys, Imitation, and Look-Alike Firearms

2. Children's and Infant Apparel

The CPSIA sets forth safety requirements for children's and infant clothing, as these products may pose hazards to children. For instance, children may accidentally strangle themselves with hood or drawstrings on children's clothing.

Additionally, children risk choking on loose buttons or sustaining burns if their clothing catches fire. Finally, special requirements apply to children's clothing with drawstrings.

Examples

Examples of children's and infant apparel products include:

①　Children's pajamas

②　Children's jackets

③　Diapers and underwear

④　Infant clothing

⑤　Tight-fitting garments

Safety Standards

Examples of safety standards applicable to children's apparel include:

a. 16 CFR Part 1120 – List of Substantial Product Hazards, which incorporates ASTM F1816–97 Standard Consumer Safety Specification for Drawstrings on Children's Upper Outerwear

b. 16 CFR Part 1610 – Standard for the Flammability of Clothing Textiles

c. 16 CFR Part 1611 – Standard for the Flammability of Vinyl Plastic Film

d. 16 CFR Part 1615 – Standard for the Flammability of Children's Sleepwear: Sizes 0 through 6X (FF 3–71)

e. 16 CFR Part 1616 – Standard for the Flammability of Children's Sleepwear: Sizes 7 through 14 (FF 5–74)

3. Children's Footwear

Children's footwear materials or chemical compositions may pose risks to children due to excessive hazardous substances (e.g., lead, phthalates) or unsafe designs (e.g., slippery soles). Therefore, children's footwear should comply with relevant safety rules. Adherence to applicable voluntary standards is also recommended.

Examples

Examples of children's footwear include:

①　Children's sandals

②　Children's sneakers

③　Children's snow boots

④　Children's lace-up shoes

⑤　Children's athletic shoes

Safety Standards

While no specific mandatory standards for children's footwear have been identified, voluntary footwear standards can be adopted to enhance product safety, such as:

a. ASTM F2412 – Standard Test Methods for Foot Protection

b. ASTM F2892 – Standard Specification for Performance Requirements for Soft Toe Protective Footwear (Non-Safety/Non-Protective Toe)

4. Children's Jewelry

Children's jewelry can be hazardous because skin-contact materials may contain harmful substances, and the products present choking or strangulation risks (e.g., in the case of long necklaces). Manufacturers of children's jewelry must therefore ensure their products meet substance restrictions and other requirements.

Examples

Examples of children's jewelry include:

①　Children's necklaces

②　Children's rings

③　Children's bracelets

④　Children's earrings

Safety Standards

No specific mandatory safety standards for children's jewelry have been identified through our research. However, compliance with standards restricting hazardous substances and adherence to voluntary requirements are critical, such as astm f2923 – Standard Consumer Safety Specification for Children's Jewelry.

5. Children's Furniture

Children's furniture can pose hazards, especially to young children. For example, clothing storage units may tip over if not anchored to walls, bunk beds can trap children, wooden stools may splinter and cause injuries, and folding mechanisms on chairs can create laceration risks.

Examples

Examples of children's furniture include:

①　Children's high chairs

②　Children's beds

③　Children's chairs

④　Children's bean bags

⑤　Children's folding chairs and stools

Safety Standards

Safety standards that may cover children's furniture include:

a. 16 CFR Part 1513 – Bunk Bed Requirements

b. 16 CFR Part 1232 – Safety Standard for Folding Chairs and Folding Stools for Children

c. 16 CFR Part 1224 – Safety Standard for Portable Bed Rails

d. 16 CFR Part 1217 – Safety Standard for Cribs for Infants and Toddlers

e. 16 CFR Part 1231 – Safety Standard for High Chairs

f. 16 CFR Part 1303 – Ban on Lead-Containing Paint and Certain Consumer Products Bearing Lead-Containing Paint

6. Mattresses

Mattresses may pose risks to children, including flammability, choking hazards from "overly soft" surfaces, potential entrapment due to poor fit, and injuries from exposed coil springs.

Several standards address these concerns and ensure product safety.

Examples

Examples of mattresses covered by the CPSIA include:

①　Children's mattresses

②　Children's mattress sets

③　Crib mattresses

Safety Standards

Examples of safety standards applicable to mattresses include:

a. 16 CFR Part 1241 – Safety Standard for Crib Mattresses, which incorporates ASTM F2933 – Standard Consumer Safety Specification for Crib Mattresses by reference

b. 16 CFR Part 1632 – Standard for the Flammability of Mattresses and Mattress Pads

c. 16 CFR Part 1633 – Standard for the Flammability (Open Flame) of Mattress Sets

7. Bicycles and Bicycle Helmets

The CPSIA specifies safety requirements for bicycles and bicycle helmets, including those designed for children. These products may pose risks to children due to harmful substances (e.g., lead), sharp edges, or other hazardous characteristics.

Manufacturers of such products must therefore ensure compliance with relevant requirements.

Examples

Examples of bicycle-related products include:

①　Children's track bikes

②　Children's sidewalk bikes

③　Children's recumbent bikes

④　Children's bicycle helmets

Safety Standards

Examples of standards applicable to bicycles include:

a. 16 CFR Part 1512 – Bicycle Requirements

b. 16 CFR Part 1203 – Safety Standard for Bicycle Helmets, which incorporates several ASTM standards by reference

8. Cribs and Cradles

The CPSIA establishes regulatory requirements for cribs and cradles. Additionally, these products are classified as "durable".

Importers or manufacturers of durable infant or toddler products must provide postage-paid product registration cards and affix permanent information labels to each product.

Examples

Examples of crib and cradle products include:

①　Children's beds (full-size)

②　Children's beds (non-full-size)

③　Children's travel cribs

④　Children's portable cradles

Safety Standards

Examples of standards applicable to cribs and cradles (incorporating ASTM standards by reference) include:

a. 16 CFR Part 1218 – Safety Standard for Cradles and Bassinets

b. 16 CFR Part 1219 – Safety Standard for Full-Size Cribs

c. 16 CFR Part 1307 – Ban on Phthalates in Children's Toys and Child Care Articles

9. Strollers and Carriages

The CPSIA sets safety requirements for the manufacture of strollers and carriages. While strollers are intended for infants and carriages for children aged 3 and under, both are classified as durable infant or toddler products by the Consumer Product Safety Commission (CPSC).

Additional safety requirements may apply to strollers and carriages to minimize the risk of death and injury associated with their use.

Examples

Examples of strollers and carriages regulated by the CPSIA include:

①　Baby carriages

②　Baby strollers

③　Three-wheeled strollers

Safety Standards

Examples of standards applicable to strollers and carriages (incorporating ASTM standards by reference) include:

a. 16 CFR Part 1227 – Safety Standard for Strollers and Carriages, which incorporates ASTM F833 – Standard Consumer Safety Performance Specification for Strollers by reference

b. 16 CFR Part 1307 – Ban on Phthalates in Children's Toys and Child Care Articles

10. Pacifiers

Pacifiers can be hazardous because children may place the entire product in their mouths, leading to choking or suffocation. The products may also break under abuse, creating potential small-part choking hazards.

Examples

Examples of pacifiers and related products include:

①　Baby pacifiers

②　Pacifier clips

③　Pacifiers with teats

④　Toy pacifiers

Safety Standards

Standards covering pacifiers, pacifier clips, and related products include:

a. 16 CFR Part 1511 – Requirements for Pacifiers

b. 16 CFR Part 1307 – Ban on Phthalates in Children's Toys and Child Care Articles

c. 16 CFR Part 1501 – Small Parts Regulation

d. 16 CFR Part 1307 – Ban on Phthalates in Children's Toys and Child Care Articles

e. ASTM F963 – Standard Consumer Safety Specification for Toy Safety

11. School and Stationery Supplies

Stationery items such as pencils or crayons must not contain excessive levels of harmful substances like lead, nickel, and mercury. Additionally, children may be vulnerable to laceration hazards from pencils or other stationery with sharp edges.

Examples

①　Pens and pencils

②　Highlighters and markers

③　Crayons and paints

④　Paper and notebooks

⑤　Scissors and staplers

Safety Standards

The Labeling of Hazardous Art Materials Act (LHAMA) may cover various school and stationery products, particularly if they are classified as art materials. Standards addressing health and safety, small parts, substance solubility, and sharp edges/points include:

a. ASTM d4236 – Standard Practice for Labeling Art Materials for Chronic Health Hazards

b. ASTM F963 – Standard Consumer Safety Specification for Toy Safety

12. Other Products

Below is a list of additional children's products referenced in the CPSC’s "Rules Requiring Third-Party Testing and Certification of Children's Products" that are not covered in the preceding sections.