US Plush Toy Compliance Testing Requirements

The US toy market is one of the largest in the world. Regardless of the country of origin, all products targeting children under 12 years old are subject to the highest standards of review by the US Consumer Product Safety Commission (CPSC). In November 2025, the CPSC initiated a recall of approximately 64,000 plush alpaca toys solely because the eye components of the toys could detach, forming small parts that pose a choking hazard to children under 3 years old. Although it may seem like a minor issue with a small component, in the US, this is sufficient to trigger a mandatory recall, full product withdrawal from the market, and substantial financial losses for the brand.

In fact, beyond the risk of small parts, US requirements for plush toys extend far further. Due to their unique material properties and structural characteristics, plush toys must also meet multiple compliance requirements related to mechanical safety, flammability, and chemical safety. This article will systematically analyze the regular compliance testing requirements for US plush toys by combining common structures and risk points of plush toys, helping enterprises identify risks in advance, avoid recalls, and ensure products smoothly enter the US market.

Physical and Mechanical Safety Requirements

Regulatory Basis: Mechanical and Physical Properties Requirements - ASTM F963-23, Standard Consumer Safety Specification for Toy Safety

The main risks of plush toys focus on structural issues such as detachment of small parts, seam breakage, loosening of plastic accessories, and exposure of fillings. Therefore, ASTM F963-23 clearly stipulates that toys must comply with the following physical and mechanical requirements:

01 Small Parts Testing

Applicable to toys for children under 36 months. Any detached component may pose a potential small part hazard. Testing is primarily conducted through pull tests, torque tests, drop tests, and seam tensile strength tests. If a component detaches during testing and can fit into the small parts test cylinder, the product is deemed non-compliant.

02 Sharp Points and Edges

Even plush toys carry the risk of internal plastic structures breaking or metal wires becoming exposed. ASTM F963 requires that toys must not have sharp points or edges after normal use and abuse testing.

03 Filling Safety

The internal filling of plush toys must not contain hard foreign objects or materials that could cause cuts or punctures. Some states, such as California and Pennsylvania, impose additional requirements on fillings (including legal labeling and material registration), which export enterprises must pay attention to.

Flammability Requirements

Regulatory Basis:

①　Flammability of Solids Requirement - ASTM F963-23, A5, Standard Consumer Safety Specification for Toy Safety

②　16 CFR Part 1500.44, Method for determining extremely flammable and flammable solids

Plush toys are typically made of plush fabrics, toy clothing materials, and other accessories. To prevent serious injuries to children from contact with fire sources, these toy materials must meet US requirements for combustion speed. Samples are cut to specified dimensions, ignited with a test flame, and the flame propagation speed is measured.

Chemical Safety Requirements

Regulatory Basis:

①　Total Lead Content in Substrate - ASTM F963-23, Section 4.3.5.2(2)(a)

②　Soluble Heavy Metals Content in Substrate - ASTM F963-23, Section 4.3.5.2(2)(b)

③　Phthalate Content – ASTM F963-23

④　Total Lead Content in Surface Coating - ASTM F963-23, Section 4.3.5.1(1)

⑤　Soluble Heavy Metals Content in Surface Coating - ASTM F963-23, Section 4.3.5.1(2)

Although plush toys may appear safe, their dyed fabrics, plastic components, and fillings may pose risks related to heavy metals or plasticizers.

01 Lead Content

①　Total lead in substrate ≤ 100 mg/kg

②　Lead in surface coating ≤ 90 mg/kg

02 Soluble Heavy Metals

Testing is conducted to determine the "leachable" heavy metals in both substrates and surface coatings, including 8 elements: lead, cadmium, chromium, mercury, arsenic, barium, selenium, and antimony.

03 Phthalates

Phthalates are mainly present in flexible PVC, rubber, or soft plastic accessories, such as toy decorations, soft rubber parts, and built-in soft components. US regulations require that the content of specific phthalates must not exceed 0.1% (1000 ppm). Routine testing includes the following phthalate substances:

①　DEHP — Di-(2-ethylhexyl) phthalate

②　DBP — Dibutyl phthalate

③　BBP — Benzylbutyl phthalate

④　DINP — Di-iso-nonyl phthalate

⑤　DIBP — Di-iso-butyl phthalate

⑥　DPENP / DnPP — Di-n-pentyl phthalate

⑦　DHEXP / DnHP — Di-n-hexyl phthalate

⑧　DCHP — Dicyclohexyl phthalate

JJR Laboratory (China) can provide compliance guidance for toys. For inquiries regarding plush toy compliance requirements, testing procedures, sample preparation specifications, or examples of report content, please contact JJR Laboratory for professional guidance and one-stop testing and certification support.