EWROI

Table of Contents
Tracking Information
Lead Content Testing
Finding a CPSC-Accepted Laboratory
Children’s Product Certificate (CPC)
Mandatory Reporting Requirement
Resources
Contact Information
Feedback on the Regulatory Robot
Disclaimer
The information provided by the Robot is not legal advice and is not to be relied or acted upon as
representing legal advice or conclusions of the CPSC or any CPSC employee. Additionally, the
information in the Robot is not promised or guaranteed to reflect the most current legal
developments.

In particular, the information provided below is wholly dependent upon information you have
entered when navigating the Robot, and may not accurately reflect the requirements applicable to
your product. No information conveyed by the Robot, or otherwise on the CPSC website, or in
other CPSC materials, should be used as a substitute for advice of competent counsel regarding
legal requirements.

Tracking Information
You indicated that your product is designed or primarily intended for children 12 years of age or
younger.

All children’s products must include permanent tracking information on the product and its
packaging, to the extent practicable. You can find out more information on the tracking label
requirement by visiting our business guidance page and by watching this short CPSC YouTube
Video. (For additional guidance on what is considered a "children's product," please review CPSC
staff's frequently asked questions.)

Please Note: The CPSC does not require you to have your tracking label certified by a CPSC-
accepted third party testing laboratory. Nor, does the CPSC require you to certify compliance with
the tracking label requirement in your Children’s Product Certificate (CPC).

Lead Content Testing

All accessible component parts of a children's product must be tested to demonstrate
compliance with the lead content limit of 100 parts per million (ppm). This requirement applies
to substrate materials in children’s products, such as metals and plastics. Lead content testing
must be conducted at a third party, CPSC-accepted laboratory.

Testing Exemptions: The Commission has determined that certain materials do not need to be
tested by a third party laboratory. To rely on the following list, the materials must be untreated
and unadulterated, and the product must be made exclusively of the following materials:

certain natural and synthetic textiles, such as cottons, wools, and polyesters, among others;
pure wood (not plywood or other composites);
paper and other similar products made from cellulosic fiber;
CMYK ink printing processes;
 certain plant-derived and animal-derived materials, such as animal glue, bee's wax, seeds, nut
shells, flowers, sea shells, leather;
certain precious, semi-precious gemstones and pearls; and
certain stainless steel and precious metals, as listed.
This list is a sampling of the determinations that the Commission has made. You can find the
complete list of material determinations at: 16 CFR § 1500.91.

There are also other lead content determinations and exemptions that the Commission has
made related to inaccessible component parts 16 CFR § 1500.87, electronic devices 16 CFR §
1500.88, and engineered wood products 16 CFR part 1252.

Section 2 of a Children’s Product Certificate (CPC) requires a list of applicable citations for the
product being certified. The citation for total lead content in substrate materials is: 15 U.S.C. §
1278a. If you are relying on the testing exemptions listed in 16 CFR § 1500.91, in Section 6,
where the CPC requires you to state where it was tested, you would insert the citation, 16 CFR §
1500.91, and indicate which materials the product is made of that would exempt it from total
lead content testing (e.g., 100% cotton). This citation method also would be required when using
other lead content determinations and exemptions found at 16 CFR § 1500.87, 16 CFR §
1500.88, and 16 CFR part 1252. CPCs are explained in greater detail later in this report.

Finding a CPSC-Accepted Laboratory

If this report indicates that your product requires third party testing at a CPSC-accepted
laboratory, you may visit: www.cpsc.gov/labsearch, to locate a CPSC-accepted laboratory.
Laboratories are available worldwide.

To ensure that you are completing the necessary testing, CPSC staff recommends that you get
estimates from a few laboratories to compare recommendations. Manufacturers and importers
must also ensure that their products are periodically tested in accordance with 16 CFR §
1107.21. The majority of children’s products will require annual testing.

Children’s Product Certificate (CPC)

Manufacturers and importers of children’s products must certify compliance with applicable
federal safety requirements in a Children’s Product Certificate (CPC). In most instances, testing
by a third-party, CPSC-Accepted Laboratory must serve as the basis for the production of your
CPC.

To find out more information on the seven (7) elements in a CPC, and to see two sample CPCs,
please visit: http://www.cpsc.gov/cpc. Possible citations for the CPC are provided in the
preceding sections of this report. Additionally, you may find our video series on CPCs helpful in
navigating this requirement:

CPSC Education Series: Children’s Product Certificates (CPC) Part 1 — The first video in the
series provides an overview of CPCs and covers the types of information needed to produce a
CPC.
CPSC Education Series: Children’s Product Certificates (CPC) Part 2 | How to Create a CPC —
The second video in the series walks the viewer through three fictitious CPC examples to
teach you how to create your own CPC.
CPSC Education Series: Children’s Product Certificates (CPC) Part 3 | Frequently Asked
Questions (FAQs) — The third video in the series covers various frequently asked questions
(FAQs) regarding CPCs.
Once you have created the CPC, you do not submit it to the CPSC, nor do you need the CPSC to
approve your CPC. Instead, CPCs must accompany each product or product shipment, be
furnished to each distributor or retailer, and be made available to the CPSC or U.S. Customs upon
request. These requirements are satisfied by either providing an actual hard copy, or by providing
the CPC electronically, e.g., through a dedicated website URL specified on your invoice. (See
these frequently asked questions (FAQs) for more information.)

Mandatory Reporting Requirement

Additionally, you should always be mindful of your legal obligation under Section 15 of the
Consumer Product Safety Act to report to the Commission when you receive information about
your product that may reasonably support the conclusion that a product (1) fails to comply with
any requirement enforced by the Commission; (2) contains a defect that could pose a hazard to
consumers; or (3) creates an unreasonable risk of injury or death. Reports can be filed through
the CPSC website at: https://www.saferproducts.gov/CPSRMSPublic/Section15/, where you can
also learn more about your legal responsibilities. There are also certain requirements about
reporting lawsuits under Section 37 of the Consumer Product Safety Act. Additional details are
available at: www.cpsc.gov/reporting, at: www.cpsc.gov/recallguidance, and in the CPSC Recall
Handbook.

This report provides a list of requirements that may apply to your product, depending upon how it
is constructed. Manufacturers and importers of record are ultimately responsible for ensuring
that their products are fully compliant with all applicable requirements.

Resources
There are several business resources that we would like to share with you:
1. Webinars/Online Trainings - the CPSC maintains a Business Education Playlist on our
CPSC YouTube Channel, providing instructional webinars on the requirements for a variety of
consumer products.
2. Newsletter - the CPSC’s Small Business Ombudsman sends out a near-monthly newsletter
letting businesses know of upcoming trainings, webinars, and regulatory activity that may
be of interest. To sign up for our Small Business Newsletter, please visit: www.cpsc.gov/
Newsroom/Subsribe, select “Small Business Ombudsman Updates,” and provide your
preferred email address.
3. Online Sellers' Safety Guide Are you a small business owner, handmaking products at home,
like stuffed toys and clothing, to sell online? Are you a small importer or drop shipper, bringing
into the United States, various kinds of products to sell in online platforms and marketplaces?
Are you reselling secondhand goods in online thrift stores or on other third-party platforms? If
you said yes to any one of those questions, then check out the CPSC’s Online Sellers' Safety
Guide.

Contact Information
After reviewing this report, if you have follow-up questions, please contact the Small Business
Ombudsman via our Online Contact Form, or by calling (888) 531-9070, or (301) 504-7945.

Feedback on the Regulatory Robot

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Thank you for using the U.S. Consumer Product Safety Commission’s Regulatory Robot!