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Toy CPSIA Testing

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01

Overview

CPSIA (Consumer Product Safety Improvement Act) is a U.S. federal law (Public Law 110-314) signed on August 14, 2008, which comprehensively upgraded safety requirements for children's products.
CPSIA is administered by the U.S. Consumer Product Safety Commission (CPSC).
The core provisions of the act cover three areas: lead content limits (Section 101), phthalate limits (Section 108), and third-party testing and certification requirements (Section 102).
CPSIA applies to all products intended for children under 12 (including toys and non-toy children's products) and is one of the most stringent children's product safety regulations in the United States.
Products that violate CPSIA requirements will be barred from import and sale, and manufacturers/importers face substantial fines and even criminal liability.
02

Applicable Product Scope

Applicable product and service categories

CPSIA applies to all "consumer products" intended for use by children under 12. A "children's product" is determined by factors including: whether product packaging or marketing implies children's use, whether consumers generally recognize the product as intended for children, and product age labeling. Specific products include: toys (plush toys, plastic toys, electric toys, etc.), children's jewelry, children's clothing, children's backpacks and school supplies, children's furniture, children's sports equipment, infant products (pacifiers, walkers, cribs, etc.), children's books and magazines, children's art and craft materials, and children's food containers and tableware.
03

Limit Requirements

Technical standards and compliance indicators

CPSIA Three Core Limit Requirements
Determination MethodTotal lead content, per CPSC-CH-E1001-08.3 (metal), CPSC-CH-E1002-08.3 (non-metal), CPSC-CH-E1003-09.1 (paint coatings).
Regulated ObjectLimitEffective Date
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Children's product substrate (total lead)100 ppm (0.01%)August 14, 2011
Children's product paint and surface coating (total lead)90 ppm (0.009%)August 14, 2009
CategorySubstance NameCAS No.Limit
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Permanently Banned (8 substances)DEHP117-81-70.1% (1000 ppm)
DBP84-74-20.1% (1000 ppm)
BBP85-68-70.1% (1000 ppm)
DINP28553-12-00.1% (1000 ppm)
DIBP84-69-50.1% (1000 ppm)
DPENP (DnPP)131-18-00.1% (1000 ppm)
DnOP117-84-00.1% (1000 ppm)
DCHP84-61-70.1% (1000 ppm)
I. Lead Content Limits (Section 101)
II. Phthalate Limits (Section 108, 2017 CPSC Final Rule)
III. Third-Party Testing and Certification (Section 102)
IV. Tracking Label Requirements (Section 103)
The above limits apply to accessible plastic components in children's toys and child care articles that can be placed in a child's mouth.
All children's products must be tested by a CPSC-accepted third-party laboratory (Accepted Laboratory) and a Children's Product Certificate (CPC) must be issued based on the test report. Testing items include lead, phthalates, and applicable toy safety standards (e.g., ASTM F963).
All children's products must bear tracking labels on the product itself and its packaging, including: manufacturer/importer name and address, place of manufacture, production date (year/month), batch number or similar identification information.
04

Third-Party Testing Process

Complete steps from application to certification

CPSIAThird-Party Testing Process
Step 1Confirm the product is a "children's product" and determine the applicable age range.
Step 2Disassemble the product to homogeneous material level and identify all accessible components (use reasonable abuse testing to determine which parts are accessible).
Step 3Send samples to a CPSC-accepted third-party laboratory for testing (accepted labs can be found at cpsc.gov/cgi-bin/labsearch).
Step 4The laboratory issues a test report which must include: laboratory information (CPSC acceptance number), product description, test items and methods, test results and determination.
Step 5The importer or manufacturer issues the CPC based on the test report.
Step 6Apply tracking labels to products.
Step 7Retain test reports and CPC for at least 5 years for inspection.
05

Certification process

Complete steps from application to certification

CPSIA Compliance Process Summary
1. Product Design PhaseAvoid using materials containing lead and phthalates.
2. Raw Material Control PhaseRequire suppliers to provide raw material compliance declarations and SGS/TUV test reports.
3. Production PhaseEstablish a quality control system and regularly inspect raw materials and finished products.
4. Pre-shipment PhaseSend samples to a CPSC-accepted laboratory for full testing.
6. Ongoing Compliance PhaseEstablish a product traceability system and cooperate with CPSC market sampling.
5. Import and sell after obtaining the CPC certificate.
06

Required Documents and Notes

Required documents and materials checklist

Applying for CPSIA testing requires the following documents: product name and model
Target age range of product (under 12 years is a children's product)
Product disassembly list and BOM (indicating material of each part)
Samples (5 to 10 grams of each accessible component material)
Packaging information (including tracking label design). Note: CPSIA's "can be mouthed" definition refers to products or components smaller than 5 centimeters that can be placed in a child's mouth. For components that cannot be mouthed and are inaccessible (e.g., secured by screws or enclosed within a hard shell), phthalate testing may be exempt. The list of CPSC-accepted laboratories is published on the CPSC website; reports from non-accepted laboratories are not recognized. The CPC must be self-issued by the U.S. importer or manufacturer; third-party laboratories do not issue CPCs. Materialchangeaftermust be re-tested. U.S. Customs has strict inspections for children'sproduct CPSIAcompliance inspections are very strict;recommendedprepare in advancecomplete compliancedocument.CPSC maximum penalty for violationscanper violation1500million USD.CPSIAwithASTM F963 relationship: ASTM F963isCPSIAaccepted toysafetystandard, CPCinmust referenceASTM F963standard.
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Why Choose Anmai Testing for Toy CPSIA Testing

Why Choose Anmai Testing

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Dongguan Anmai Testing Technology Co., Ltd. Address: Room 1005, Baishihui, No. 286 Changqing South Road, Chang'an Town, Dongguan City | Email: anmai@dganmai.com | Business Hours: Monday to Saturday 9:00-18:00 | Guangdong ICP No.20058375No.
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