United States - Children's product (non-toy)
US compliance requirements for children's product (non-toy)
Products designed or intended primarily for children but without play value. In the US these trigger the full CPSIA regime (testing, certification, tracking labels); in the EU/UK they rely on general product safety plus chemical rules.
For example: kids' backpack, children's tableware, kids' hair accessories, children's sunglasses.
If the product has play value it is legally a toy — use the toy category instead (EU Toy Safety Directive / UK Toys Regulations). US 'children's product' means designed or intended primarily for children 12 or younger: CPSIA then requires third-party testing at a CPSC-accepted lab, a Children's Product Certificate, lead and phthalate limits, and permanent tracking labels. The forChildren attribute is inherent to this category. Children's sunglasses are PPE in the EU/UK (Regulation 2016/425) — verify and see the ppe-safety-gear category. Children's food-contact items (tableware, bottles) also engage food contact materials law — see food-contact category notes. Adding electronics via the attribute bundles brings UKCA-marked legislation with it — UKCA marking then applies.
Base requirements3 instruments
California law requiring businesses to give a clear and reasonable warning before knowingly and intentionally exposing anyone in California to a chemical on the state's Proposition 65 list, and prohibiting knowing discharges of listed chemicals into drinking water sources. It is a warning law, not a ban — products containing listed chemicals may still be sold if properly warned.
Key obligations
- 01Provide a clear and reasonable warning before knowingly and intentionally exposing anyone in California to a chemical listed under Proposition 65, unless the exposure is low enough to qualify for an exemption.source
- 02Do not knowingly discharge listed chemicals into sources of drinking water in California.source
- 03Track the chemical list: OEHHA maintains the list, which must be updated at least once a year and has grown to include over 800 chemicals (naturally occurring and synthetic) listed for cancer, birth defects or other reproductive harm since first publication in 1987. The current list is dated December 8, 2025.source
- 04Once a chemical is newly listed, businesses have 12 months before the warning requirement takes effect for that chemical.source
General-use consumer products need a General Certificate of Conformity (GCC) only if a CPSC rule, ban or standard applies to them, and every business in the supply chain has an ongoing duty to report potential substantial product hazards to CPSC. There is no pre-market approval: CPSC does not approve products before sale.
Key obligations
- 01Where a general-use product is subject to a consumer product safety rule (or a similar rule, ban, standard or regulation under any other CPSC-enforced statute), the domestic manufacturer or importer must certify compliance in a written General Certificate of Conformity (GCC), based on a test of each product or a reasonable testing program. The GCC and supporting information must be in English.source
- 02Only the importer (for products made outside the US) or the domestic manufacturer (for US-made products) must certify (16 CFR 1110.7). The certificate must be available to CPSC as soon as an imported shipment is available for inspection, or before a domestic product enters commerce, and must accompany the shipment and be furnished to distributors and retailers.source
- 03Section 15(b) duty to report (15 U.S.C. 2064(b)): every manufacturer, distributor and retailer who obtains information reasonably supporting the conclusion that a product fails to comply with an applicable rule or standard, contains a defect which could create a substantial product hazard, or creates an unreasonable risk of serious injury or death must immediately inform the Commission.source
- 04"Immediately" means within 24 hours of obtaining reportable information (16 CFR 1115.14(e); CPSC: "A company must report to the Commission within 24 hours of obtaining reportable information"). A firm genuinely uncertain whether information is reportable may investigate, but the investigation should not exceed 10 working days unless a longer period is demonstrably reasonable. CPSC's advice is "when in doubt, report" — no injury needs to have occurred.source
The CPSIA imposes strict requirements on children's products sold in the US: third-party testing at a CPSC-accepted laboratory, a written Children's Product Certificate, permanent tracking labels, and tight limits on lead and phthalates. A children's product is one designed or intended primarily for children 12 years of age or younger.
Key obligations
- 01Before importing or distributing, submit sufficient samples of a children's product subject to a children's product safety rule to a third-party, CPSC-accepted laboratory for compliance testing. Self-testing or in-house testing cannot substitute for third-party testing.source
- 02The domestic manufacturer or importer must issue a written Children's Product Certificate (CPC), based on the third-party test results, certifying compliance with each applicable children's product safety rule. The CPC and supporting test reports must be in English; no set template is required as long as the 7 required elements are present and accurate.source
- 03Place permanent, distinguishing tracking marks on the product and its packaging, to the extent practicable, enabling the manufacturer and the ultimate purchaser to ascertain the manufacturer or private labeler, the location and date of production, and cohort information (batch, run number, or other identifying characteristic) (Section 103 CPSIA, codified at 15 U.S.C. 2063(a)(5)).source
- 04Total lead content: a children's product containing more lead than the statutory limit is treated as a banned hazardous substance. The limit phased down from 600 ppm to 300 ppm and then to 100 ppm beginning three years after enactment (i.e. from 14 August 2011) (15 U.S.C. 1278a).source
If your product also...
Extra regulations triggered by specific features
Has radio / wireless (Wi-Fi, Bluetooth, cellular, GPS, RFID/NFC)
FCC Part 15 — Intentional Radiators (Equipment Certification)
Plugs into mains power (50–1000 V AC)
OSHA Nationally Recognized Testing Laboratory (NRTL) Program — UL and other NRTL listingFCC Part 15 — Unintentional Radiators (Supplier's Declaration of Conformity)
Documents you will need
Deduplicated across the regulations above
- Warning label / sign artworkNo certificate or government filing is required; compliance is demonstrated by the warning itself (label, shelf sign/tag, or website warning for internet sales) meeting the content and transmission methods of 27 CCR Article 6.source
- Written notice to retail sellersThe regulations allocate responsibility along the supply chain: manufacturers/suppliers can discharge their duty by providing a warning or a written notice to the retail seller under 27 CCR 25600.2(b) and (c); for internet purchases before January 1, 2028, a retailer is not responsible for posting an updated short-form warning online until 60 calendar days after receiving an updated warning or written notice.source
- General Certificate of Conformity (GCC)Must contain 7 elements (16 CFR 1110.11): product identification; citation to each rule certified to; identity (name, full mailing address, phone) of the certifying manufacturer or importer; contact for the custodian of test records; date and place of manufacture; date(s) and place(s) of testing; identification of any third-party laboratory relied on. Hard copy or electronic form is acceptable; electronic certificates need a unique identifier and accessible URL.source
- Records supporting certificationKeep test results/reasonable-testing-program records; CPSC suggests issuers maintain supporting test records for at least three years (note to 16 CFR 1110.11(d)). The certifying entity remains legally responsible for the accuracy and completeness of certificate information.source
- Section 15(b) reportReport to CPSC within 24 hours of obtaining reportable information. If another responsible party has already adequately informed CPSC, a firm need not re-report, but documentation demonstrating that is recommended. 16 CFR Part 1115 sets out the substantial product hazard reporting framework.source
- eFiled certificate data (imports, from 8 July 2026)Beginning July 8, 2026, importers of most regulated consumer products must electronically file (eFile) certificates of compliance with U.S. Customs and Border Protection via a Partner Government Agency Message Set.source
- Children's Product Certificate (CPC)Must contain 7 elements: product identification; citation to each children's product safety rule certified to; identity (name, full mailing address, phone) of the certifying manufacturer or importer; contact for the records custodian of test results; date and place of manufacture; date(s) and place(s) of testing; identification of the third-party CPSC-accepted laboratory. Must be in English.source
- Third-party test reportsSupporting test reports must be in English; the firm on the certificate must facilitate provision of test reports when requested. CPSC suggests issuers keep supporting test records for at least three years (16 CFR 1110.11 note).source
Frequently asked
Does a Proposition 65 warning mean the product is banned or unsafe?+
No. Prop 65 does not ban any product — it is a right-to-know law. A warning means the business believes the product can expose Californians to a listed chemical above the level where a warning is required (or the business is warning out of caution without measuring exposure).
Does CPSC approve my product before I can sell it?+
No. CPSC does not provide pre-market approvals of products. If a mandatory rule applies you must test (or run a reasonable testing program), certify with a GCC, and keep records — but you do not submit the product to CPSC for sign-off, and you must not claim a product is 'CPSC-approved'.
What counts as a children's product?+
A consumer product designed or intended primarily for children 12 years of age or younger. 'Primarily' matters: a product used by all ages (like an ordinary pen or a TV) is a general use product even if children use it. CPSC weighs the manufacturer's stated intent, packaging and marketing, common consumer perception, and its Age Determination Guidelines.
Other markets, same product
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