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USA · Children's products

CPSIA requirements for children's products made in India

A children's product is one designed or intended primarily for children 12 and under. Under the CPSIA it must meet the applicable CPSC rules, such as 100 ppm total lead, 90 ppm lead in paint and phthalate limits for toys. It must be tested by a CPSC-accepted lab, carry tracking labels and be covered by a Children's Product Certificate.

Definition
Designed or intended primarily for children 12 years or younger (16 CFR 1200)
Certificate
Children's Product Certificate (CPC), issued by the importer
Testing
Third-party lab accepted by CPSC; periodic retesting, at least yearly by default
Lead
100 ppm total lead in accessible parts; 90 ppm in paint and coatings
Phthalates
8 phthalates, each max 0.1%, in toys and child care articles (16 CFR 1307)

Key takeaways

  • Whether a product is a children's product depends on how it is designed, marketed and packaged, not only on its size.
  • A CPC must rest on tests by a third-party lab whose accreditation CPSC has accepted. Factory in-house reports do not qualify.
  • Lead limits apply to every accessible part: 100 ppm total lead in substrates and 90 ppm in paint. Paint does not count as a barrier.
  • Each product and its packaging need permanent tracking information: maker or importer, place and date of production, and batch.
  • Durable infant and toddler products, such as cradles, high chairs and children's folding chairs, also need a registration card and permanent marking.

What counts as a children's product

The Consumer Product Safety Act defines a children's product as a consumer product designed or intended primarily for children 12 years of age or younger. CPSC's rule at 16 CFR 1200 lists the factors it weighs: the maker's statement of intended use and any label, how the product is packaged, displayed and advertised, whether it is commonly recognized as being for children, and the CPSC age-determination guidelines.

Colours, motifs and features that appeal mainly to young children push a product into the category. A plain wooden stool is a general-use product; the same stool painted with cartoon animals and sold in a nursery range is likely a children's product. Products intended for all ages but mainly used by people over 12 are general-use items. For Indian makers, the decision should be made with the importer before sampling, because it changes the testing, labelling and certificate.

What the CPSIA requires

RequirementRuleWhat it means
Total lead contentCPSIA section 101; 16 CFR 1500.87–1500.91No more than 100 ppm lead in any accessible part. Paint, coatings and electroplating are not a barrier that makes lead inaccessible.
Lead in paint and surface coatings16 CFR 1303No more than 0.009% (90 ppm) lead in the dried paint film
Phthalates16 CFR 1307Children's toys and child care articles must not contain more than 0.1% of DEHP, DBP, BBP, DINP, DIBP, DPENP, DHEXP or DCHP in any plasticized or other component that may contain them
Product safety rulesFor example 16 CFR 1250 (toys, ASTM F963), 1513 (children's bunk beds), 1232 (children's folding chairs and stools), 1610 (clothing textiles)Whatever product-specific rules apply, tested by an accepted lab
Tracking labelsCPSIA section 103 (CPSA section 14(a)(5))Permanent marks on the product and packaging, to the extent practicable
Registration card and marking16 CFR 1130For durable infant and toddler products only
Children's Product Certificate16 CFR 1107 and 1110Issued by the importer, listing every rule and the lab that tested it; eFiled at US entry since 8 Jul 2026
Sources: eCFR title 16, parts 1130, 1303, 1307, 1500, 1110; CPSC guidance, reviewed 13 Oct 2026.

A child care article is a product designed to help children aged 3 and under sleep, feed, suck or teethe. A children's toy is a product for a child 12 or under to use in play.

Third-party testing, exemptions and retesting

A CPC must be based on tests by a third-party conformity assessment body: a lab whose accreditation CPSC has accepted for the specific test methods. CPSC publishes the list of accepted labs, so check the lab and its scope before samples are sent. The rules in 16 CFR 1107 then require:

  • Material-change testing when a design, component, component supplier or process changes in a way that could affect compliance.
  • Periodic testing during continued production, at least once a year by default, or every two or three years under the longer options in 16 CFR 1107.21.
  • Records of tests and the CPC kept for at least five years.

Some materials are exempt from lead-content testing, though not from the limit. Under 16 CFR 1500.91 they include untreated wood, paper, natural and manufactured textile fibres that are only dyed, and plant- and animal-derived materials such as leather, bone and shell. Brass, other base metals, paints, prints and surface treatments are not on that list, and the exemption is lost if the material is treated or adulterated with something that could add lead. The CPC must still name every applicable rule and state any testing exclusion relied on.

Tracking labels and registration cards

Tracking labels apply to all children's products. The permanent marks must let anyone find the manufacturer or private labeler, the place and date of production, and cohort information such as a batch or run number. CPSC accepts the importer's name, and accepts codes as long as a consumer can find out who interprets them. Hangtags do not count as permanent. If a product cannot practicably be marked, the packaging still must be.

Durable infant or toddler products, for children under 5, have extra duties under 16 CFR 1130. The list includes cribs, toddler beds, high chairs, bassinets and cradles, changing products, children's folding chairs and stools, gates and bed rails. Each product needs:

  • A postage-paid consumer registration card supplied with the product.
  • A permanent mark with the manufacturer's (importer's) name and contact details, model name and number, and date of manufacture.
  • A record of registrations, used only for recalls and safety alerts.

What this means for Indian toy, furniture and décor makers

  • Painted wooden toys and furniture. Every paint colour and lacquer needs a lead-in-paint result, and the substrate and any metal parts need total-lead results. Colours mixed locally from different batches are the main risk.
  • Brass and metal décor. Moradabad brass and other alloys are not exempt from lead testing. Brass can contain lead, so a children's range needs testing of each alloy.
  • Soft and textile items. Dyed cotton and wool are exempt from lead testing, but prints, glitter, embellishments, buttons and vinyl parts are not. Plastic parts of toys and child care articles need phthalate tests.
  • Cradles, high chairs and kids' chairs. These are durable infant or toddler products and may also have their own CPSC safety standard.
  • Records. Batch codes on goods and cartons must link to production records the factory keeps, or a recall cannot be targeted.

What an inspection can verify, and what needs a lab

An inspector at the factory can checkOnly a lab can establish
Tracking labels on products and cartons, legible and permanent, with batch and date that match production recordsTotal lead in substrates and lead in paint
Registration cards and permanent marking on durable infant and toddler productsPhthalate content of plastic and coated parts
Paints, alloys, plastics and trims in production match those in the CPSC-accepted lab reportMechanical and physical tests of ASTM F963 and other product rules
Age grading, warnings and packaging match the agreed specificationWhether a changed material still complies

How Clear To Load checks this in India

On a home décor and handicrafts inspection or a furniture inspection, the inspector checks tracking labels, cards and markings, and compares paints, metals and trims with your lab reports. For periodic or material-change testing, we pull and seal samples for a CPSC-accepted lab you choose through lab testing coordination, and check the report against the goods. We have no partner labs and take no commissions.

The report arrives within 24 hours and ends in Cleared to load, Hold or Not cleared. The CPC stays the importer's legal statement. Book an inspection to add these checks.

Sources

  1. 16 CFR Part 1200, Definition of Children's Product (eCFR)
  2. 16 CFR Part 1307, Phthalates in Toys and Child Care Articles (eCFR)
  3. 16 CFR 1500.91, Lead content determinations (eCFR)
  4. 16 CFR Part 1130, Registration of Durable Infant or Toddler Products (eCFR)
  5. 16 CFR 1107.21, Periodic testing (eCFR)
  6. CPSC: Children's Product Certificate
  7. CPSC: Tracking Label business guidance

Frequently asked questions

Is a children's room décor item a children's product?

If it is designed or marketed primarily for children 12 and under, usually yes. CPSC looks at the stated use, labelling, packaging, advertising and appeal to children. Décor for a nursery bought by adults can still be a children's product.

Can our factory's in-house lab test for the CPC?

Only if CPSC has accepted it as a firewalled conformity assessment body for those tests. Otherwise CPC testing must go to an independent lab whose accreditation CPSC has accepted for the test methods needed.

Does unpainted wood need lead testing?

No. Untreated wood is exempt from lead-content testing under 16 CFR 1500.91, but it must still meet the 100 ppm limit and the CPC must still list the rule. Paint, stains and metal fittings on the item do need testing.

Do phthalate limits apply to all children's products?

No. 16 CFR 1307 applies to children's toys and child care articles. A children's chair or a wall hanging that is not a toy or child care article is not subject to it, though buyers may ask for the test anyway.

How often must a children's product be retested?

At least once a year during continued production by default, and whenever a material change could affect compliance. 16 CFR 1107.21 allows longer intervals under a production testing plan or ISO/IEC 17025 continued testing.

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