What is CPSIA Compliance Testing

What is cpsia?

CPSIA is a landmark regULation for consumer product safety, which provides new and important standards and enforcement tools for the CPSC to revise and optimize multiple rules (including the Consumer Product Safety Act). CPSIA mainly includes provisions related to lead, phthalates, toy safety, durable infant or toddler products, third-party testing and certification, tracking labels, imports, ATVs, civil and criminal penalties, and also provides the public with an open database for querying hazard reports. Meanwhile, CPSIA repealed a controversial restriction on agency funding and increased the number of originally approved CPSC commission members from 3 to 5.

On August 14, 2008, U.S. President George W. Bush officially signed the Consumer Product Safety Improvement Act (CPSIA/HR4040) into law. This act is the most stringent consumer protection legislation since the establishment of the Consumer Product Safety Commission (CPSC) in 1972. In addition to imposing stricter requirements on lead content in children's products, the new act also sets new limits on the content of harmful phthalates in toys and children's care products. Furthermore, the act mandates the establishment of a public consumer product safety database and requires that certain children's products must have test reports issued by independent third-party laboratories recognized by the commission before being imported into the United States.

CPSIA impacts all industries in the United States that manufacture, import, and distribute toys, clothing, and other children's products and care items. All manufacturers shall ensure that their products comply with all the provisions, bans, standards, or rules of this act. As of April 25, 2018, the CPSIA Act has effectively prohibited the use of 8 different phthalates in children's toys and children's care products at levels exceeding 0.1%.

The list of prohibited phthalates is as follows:

①　Di(2-ethylhexyl) phthalate (DEHP)

②　Dibutyl phthalate (DBP)

③　Butyl benzyl phthalate (BBP)

④　Diisononyl phthalate (DINP)

⑤　Diisobutyl phthalate (DIBP)

⑥　Dipentyl phthalate (DPENP)

⑦　Di-n-hexyl phthalate (DHEXP)

⑧　Dicyclohexyl phthalate (DCHP)

CPSIA also requires domestic manufacturers or importers of non-children's products to sign a General Certificate of Conformity (GCC). The GCC applies to products regulated by consumer product safety rules or similar CPSC rules, bans, standards, or commission-enforced regulations.

For testing, CPSIA standard testing must be conducted by laboratories authorized and recognized by the U.S. CPSC (Consumer Product Safety Commission), and the authorization can be queried on the CPSC website. In addition, since CPC certificate testing involves many chemical tests, which are related to the material of the product. The more materials a product has, the higher the cost. According to chemical testing rules, different colors of the same material also need to be tested separately. Therefore, it is recommended that sellers directly test raw materials to avoid repeated charges and unnecessary operations.

General Requirements for Children's Products

CPSIA defines the term "children's products" and sets forth the following general requirements for children's products:

①　Comply with all applicable children's product safety rules;

②　Undergo compliance testing by a CPSC-recognized laboratory, unless there are other exceptions;

③　Have a written Children's Product Certificate (CPC) to provide evidence of product conformity; and

④　Have permanent traceability information affixed to the product or its packaging.

CPSIA Requirements for Lead and Phthalates

CPSIA (HR4040) sets forth requirements for lead and phthalates in the following sections:

· Section 101: Lead-containing children's products; Lead-containing paint regulations

· Section 102: Mandatory third-party testing for certain children's products

· Section 103: Traceability labels for children's products

· Section 104: Standards for durable infant products and consumer registration

· Section 105: Labeling requirements for toy and game advertisements

· Section 106: Mandatory Toy Safety Standards

· Section 107: Research on preventable minor childhood injuries and deaths related to consumer products

· Section 108: Prohibition on the sale of certain products containing phthalates

cpsia testing Content

cpsia certification testing is classified by material into metal materials and non-metal materials. Among them, metal materials are mainly tested for total lead content, while non-metal materials are mainly tested for total lead content and phthalates.

Scope of cpsia testing Products

After November 2008, CPSIA certification strengthened the scope of testing and certification and imposed more stringent testing standards. CPSIA certification mainly covers children's toys, beds, walkers, strollers, school supplies, etc.

①　Lead content testing for toys/children's products and coatings/paints;

②　Small parts testing for choking hazards;

③　Pacifiers/teethers;

④　Cribs with railings;

⑤　Children's metal jewelry;

⑥　Baby inflatable bouncers, baby walkers, jump ropes.

CPSIA Certification Process

①　Determine product testing items

②　Fill out the test application form, provide product information, and confirm testing standards

③　Sample delivery and receipt: The applicant arranges sample delivery

④　Product testing

⑤　Issue a report if the test is passed

CPSIA Certification Testing Time

For regular children's products, applying for CPSIA certification testing takes one week. For more complex children's products, the time may vary.

Mandatory Testing and Certification under CPSIA

The CPSIA Act expands the scope of products requiring testing and certification. All products controlled by the standards, bans, and implementation rules formulated by the CPSC under this act are requiRED to undergo testing and certification. Such testing and certification requirements came into effect on November 12, 2008.

The CPSC will recognize testing laboratories either directly or by designating independent accreditation bodies. However, laboratories controlled by children's product manufacturers must be recognized by the CPSC.

CPSIA Notes

One year after the regulation takes effect (August 14, 2009), manufacturers of children's products must affix permanent, clear, and prominent marks on their products and related packaging, enabling consumers to identify and confirm the manufacturer's name, production date, place of origin, and other relevant production information, thereby ensuring product traceability.

Unless a product meets the applicable safety requirements or standards of the regulation or standard, it is prohibited for consumer product advertisements or the labels and packaging of such products to contain references to consumer product safety regulations or voluntary consumer product safety standards.

The act will be continuously updated and improved as it is implemented, so please pay close attention to updated information. In addition to meeting the requirements of this regulation, attention should also be paid to additional requirements of U.S. states such as California Proposition 65, as well as requirements of other regulations, such as toy safety requirements such as ASTM, electronic product requirements such as FCC, and requirements for hazardous substances related to other federal regulations outside this act.

Reference of Toys Tested by China JJR Laboratory

China JJR Laboratory can provide one-stop services for combustion testing, electrical safety, toy safety, and hazardous substance limit testing, including preliminary evaluation, preparation and submission of relevant materials, full follow-up of testing, as well as report interpretation, data analysis, and rectification suggestions.