CPSC / CPSIA Tests

The CPSC, the U.S. Consumer Product Safety Commission, is a federal agency responsible for protecting the public from unreasonable risks of injury or death associated with consumer products. Established in 1972 under the CPSA, the Consumer Product Safety Act, it enforces a wide range of safety standards. One of its most significant updates came with the 2008 CPSIA, the Consumer Product Safety Improvement Act, a groundbreaking law enacted in response to notable recalls involving dangerous children's products, such as toys containing excessive amounts of lead.

The U.S. Consumer Product Safety Commission (CPSC) has significantly strengthened product safety regulations, particularly for children's products (typically those intended for children 12 and under). It has established strict limitations on harmful substances, mandatory third-party testing, certification requirements, and follow-up labeling. By 2025, these regulations remain fundamental, with ongoing updates to include new voluntary standards such as the ASTM F963 Standard Consumer Safety Specification for Toy Safety for toys.

Previously, many children's products entered the market with minimal independent safety verification. The CPSIA changed this by mandating third-party testing to ensure compliance with federal safety regulations. This helps prevent exposure to toxins such as lead and phthalates, choking hazards, flammability risks, and other dangers. Failure to comply with these regulations can lead to heavy penalties, product recalls, shipments seized at customs, and damage to brand reputation. Today, various platforms require proof of compliance from sellers, such as children's product certification (CPC).

Under CPSIA, children's products must meet several essential requirements:

• Safety compliance: Products must comply with all applicable CPSC rules, prohibitions, or standards. These include lead (100 ppm in substrates, 90 ppm in surface coatings), phthalates (0,1 percent in some components), small parts (for choking hazards), and toy safety limits under ASTM F963.
• Third-party testing: Unlike general consumer products, children's products must be tested by a CPSC-accredited laboratory. These laboratories hold ISO/IEC 17025 accreditation and are registered with the CPSC for specific tests. Testing includes initial certification, periodic testing (for ongoing production), and testing after material changes. Exemptions exist for certain materials (e.g., virgin wood, some textiles) or for small batch manufacturers. Component part testing is permitted where suppliers provide certified results for parts, reducing costs for finished product manufacturers.
• Children's Product Certificate (CPC): After passing the tests, the manufacturer or importer issues a children's product certificate. This document details the product, the tests performed, the laboratory used, and the declaration of conformity. This document should be included with shipments and provided to retailers and distributors upon request. For products not intended for children, a general certificate of conformity (GCC) is usually required, based on a reasonable testing program rather than mandatory third-party laboratories.
• Tracking labels: Permanent labels on the product and packaging must include manufacturer information, production date/place, batch number, and other information for traceability in case of recalls.
• Additional rules for specific products: Durable baby or toddler products (e.g., cribs, strollers) have additional requirements for recalls, such as product registration cards.

CPSIA (third-party testing to ensure compliance with federal safety regulations) generally follows these steps:

• Determining product eligibility: The product must primarily be designed for children aged 12 and under (general use items such as clothing in children's sizes may be eligible).
• Determining applicable tests: Common tests include lead/phthalates, small parts (16 CFR 1501 standard), flammability (16 CFR 1610 standard), sharp edges/points, and ASTM F963 standard for toys.
• Selecting a CPSC-accredited laboratory: For the required tests, search for laboratories accredited by the CPSC in the database.
• Sample submission for testing: Laboratories perform destructive or non-destructive tests as required.
• Certificate issuance: Based on successful reports, a Children's Product Certificate (CPC) is created and distributed.
• Continuous compatibility must be ensured: Periodic tests should be carried out (e.g., annually or according to production volume) and retested if materials/suppliers change.

The CPSIA framework is stable, but the CPSC continues to implement updated voluntary standards. For example, revisions to the standards for stationary activity centers and non-full-size cribs will come into effect in 2025, improving safety features. The organization is also focusing on emerging issues such as button batteries and furniture tipping.

To ensure compliance,

• Collaboration with accredited laboratories should be established during the design phase.
• Detailed records must be kept for at least five years.
• To reduce costs, component testing should be performed as much as possible.
• To avoid delays at customs, tests must be done before entering the US.

CPSIA testing has significantly reduced injuries from children's products over the past decade. These tests prioritize independent verification, ensuring safer toys, clothing, and equipment for children. Proactive manufacturers and importers not only avoid sanctions but also boost consumer confidence.

The basic CPSIA tests required for most children's products are as follows:

• Substrate lead content: The lead content in materials (plastic, metal, wood) is checked. It should not exceed 100 ppm (parts per million).
• Lead in surface coatings: Lead in paints, coatings, or varnishes is checked. It should not exceed 90 ppm.
• Phthalates: Plasticizers (such as DEHP, DBP, BBP, DINP, DIDP, DnOP) in plasticized parts are controlled. Each should not exceed 0,1% (1.000 ppm).
• Small parts: Choking hazard from removable parts is checked. Must not fit in the shock test cylinder (for children 3 years and under).
• Sharp edges and points: The risk of cuts or punctures is checked. There should be no dangerous sharp edges or points.
• Usage and abuse tests: Durability (dropping, torque, pulling, compressing) is checked under normal/predictable use. No danger should occur after stress.
• Flammability (textiles): The burning rate of fabrics is checked. It should be a maximum of 2,54 mm/second or it should self-extinguish.
• Toy safety (ASTM F963 standard): Compliance with this standard (mechanical, chemical, labeling, etc.) is checked. This standard is no longer a voluntary standard under CPSIA, but a mandatory one.

For many years, our organization, with its competent and experienced team, has been understanding the needs of its clients, providing the advanced testing services they require, and assisting them in the establishment, implementation, and improvement of management systems. Within this framework, CPSC/CPSIA testing services are also provided to businesses.