If you're selling children's products in the US, the CPC is almost impossible to avoid. This article explains what it is, which regulations it rests on, what the certificate must contain, and what testing sits behind it.
What the CPC Is, and Its Legal Basis
The CPC (Children's Product Certificate) is a certificate of conformity required under the Consumer Product Safety Improvement Act (CPSIA), overseen by the US Consumer Product Safety Commission (CPSC), with format requirements set out in 16 CFR Part 1110. It applies to products designed or intended primarily for children 12 years of age or younger. Importantly, the CPC is not a test item in itself — it is a compliance declaration that the manufacturer or importer issues and signs, based on passing third-party test results.
Which Products Need a CPC
Any product determined to be a "children's product" generally needs a CPC before entering the US market. Common categories include:
- Toys
- Children's apparel, children's furniture, and infant products
- Children's stationery and tableware
- Children's jewelry and children's electronics
Whether a product is a children's product depends on factors the CPSC considers together — the manufacturer's statements and labeling, packaging and marketing, whether the product is commonly recommended for children, and how similar products are generally perceived — not simply the category name. Typical gray areas: an adult insulated cup with a cartoon design, or a child-sized craft item with no stated age range, can easily be judged to be a children's product.
What a CPC Must Contain
Under 16 CFR Part 1110, a compliant CPC includes:
- Identification of the product (name, model, etc.)
- A citation to each applicable CPSC safety rule, ban, or standard
- The name, address and contact information of the manufacturer or importer
- Contact information for the person maintaining test records
- The date and place of manufacture
- The date and place of testing
- The name, address and contact information of the third-party lab that performed the testing (which must be a CPSC-accepted laboratory)
Missing any one of these can cause the certificate to be treated as non-compliant and rejected at customs or during platform review.
Common Test Items Behind a CPC
A CPC rests on test results, and the applicable tests typically include:
- Lead content: 100 ppm limit for substrate in children's products (CPSIA Section 101); 90 ppm for surface coatings (16 CFR Part 1303)
- Phthalates: limits on eight specified phthalates in children's toys and child care articles (16 CFR Part 1307, generally 0.1% per phthalate)
- ASTM F963 toy safety standard: a mandatory toy standard via 16 CFR Part 1250, covering mechanical and physical properties, flammability, and specific element migration
- Small parts: products for children under 3 must not contain detachable small parts (16 CFR Part 1501)
- Textile flammability: children's apparel under rules such as 16 CFR Part 1610
- Tracking labels: products and packaging need markings enabling batch traceability, a CPSIA requirement
Which items apply depends on the product's materials and structure — not every product needs every test.
Two Points Often Overlooked
- The lab must be CPSC-accepted: testing for children's products can't be done in-house or at an arbitrary lab — the lab must be on CPSC's accepted list, with accreditation scope covering the relevant tests
- The CPC must be kept current: if materials, suppliers or processes change materially, existing reports and the CPC may no longer apply and retesting may be needed. CPSC has also introduced electronic filing (eFiling) of certificate data for imports — confirm the latest effective dates and scope on CPSC's official notices before shipping
Cost and Timeline Reference (for budget planning only, not a quote)
- Simple single-material products (such as plastic toys): testing typically takes about 1-2 weeks
- Multi-material, multi-component products (such as toys with electronics): more test items, typically about 2-3 weeks
- Testing cost rises with the number of items and material types — generally from a few hundred to a few thousand US dollars per product, depending on the combination of tests
If the product must also meet toy standards, battery safety or radio requirements, the overall timeline is longer — running tests in parallel is recommended.
Frequently Asked Questions
Q: Who issues the CPC? A: The US importer or overseas manufacturer compiles and signs the CPC based on test reports from a CPSC-accepted third-party lab. The lab supports with testing; it does not issue the CPC for you.
Q: Does the CPC need to ship with the goods? A: It must be available promptly when customs, regulators or retailers ask for it. Keep it on file — some sales channels (such as Amazon and Walmart) request it during listing review.
Q: Do adult products need a CPC? A: Purely adult products don't need a CPC but must meet other applicable requirements such as a General Certificate of Conformity (GCC); the key question is whether the product could be treated as a children's product.
If you're unsure whether your product needs a CPC, or want to know which tests apply, send us the product details for an initial assessment and a testing plan.