US Regulatory Requirements for Children’s Products

Children's products
A children’s product is a consumer product primarily intended for a child 12 years of age or younger.

The CPSIA significantly changed the landscape for manufacturing and selling children’s products – defined as any consumer product intended for a child 12 years of age or younger. Thus the scope is quite broad and includes things from clothing, to toys, to school supplies, to diapers, …, including new and used items.

How to Comply with the US CPSIA Regulation

A US based manufacturer (or a foreign one with offices in the US) or the US based importer is required to “furnish” a Children’s Product Certificate (CPC) that is based on a third party laboratory test to applicable safety rules and standards. The CPSIA requirements include labeling for small parts for some products and tracing marks for all children’s products.

Harmonization

EU toy safety standards and US toy safety standards are not harmonized. There is the problem of using two different measurement systems for setting limits and specifying measurement requirements. Also, generally, the EU regulates more heavy metals and chemicals that the US requires.

Fragmentation

Some US states, notably Washington and California, have created their own additional requirements for children’s product safety. For the most part, these requirements deal with chemicals not included in ASTM-F963 or the CPSIA.

Finding Ways to Reduce Cost

There are two primary methods for reducing the cost of compliance to US safety regulations: (1) the component parts rule, and (2) determinations. The component parts rule is useful to nearly all manufacturers that utilize surface coatings or who use a single component on multiple products. Determinations can be used to significantly reduce cost when natural materials like wood, paper board, and cotton fabrics are part of a finished good.