Generally, all children's products require certification and testing. While there are some limited exceptions (discussed in the frequently asked questions section), you should begin your analysis with the assumption that your children's product will likely require third party testing for the applicable children's product safety rules.
Certification and Third Party Testing
All manufacturers, importers, and private labelers of children's products must certify that their children's products comply with all applicable children's product safety rules. The CPSC has provided a model Children's Product Certificate (CPC) (pdf).
Written certification for each children's product must be based upon passing test results obtained from the required third party testing at a CPSC accepted laboratory.
(Different requirements are in effect for manufacturers, importers, and private labelers of non-children's, or general use, products.)
What is third party testing?
Third party testing means testing performed by a third party accredited laboratory that the CPSC has accepted to perform the specific tests for each children's product safety rule. Nearly all children's products are required to undergo third party testing.
How do I identify the applicable federal consumer product safety laws for my product?
All children's product safety rules for which testing and certification is required are listed on the CPSC's website with our List of Accredited Testing Laboratories.
Where do I locate a CPSC-accepted laboratory?
CPSC's List of Accredited Testing Laboratories provides a complete list of (i) children's product safety rules, and (ii) the labs whose accreditation has been accepted by the CPSC to test for compliance with those rules. Suggestions for how to navigate our List of Accredited Testing Laboratories are included in the FAQ below.
Where do I learn more?
This page serves as the primary resource page for all information related to the certification and third party testing for children's products.
Resources
- FAQs - Certification and Third Party Testing
- CPSC-accepted testing laboratories
- Sample children's product certificates (CPC) [PDF]
- Testing and Labeling Pertaining to Product Certification, Final Rule, November 8, 2011 [HTML]
- Testing and Labeling Pertaining to Product Certification, Final Rule (with complete preamble), November 8, 2011 [Text] [PDF]
- Conditions and Requirements for Relying on Component Part Testing or Certification, or Another Party's Finished Product Testing or Certification, to Meet Testing and Certification Requirements, Final Rule, CPSC November 8, 2011 [HTML]
- Conditions and Requirements for Relying on Component Part Testing or Certification, or Another Party's Finished Product Testing or Certification, to Meet Testing and Certification Requirements, Final Rule (with complete preamble), , November 8, 2011 [Text] [PDF]
Undue Influence Training
If a manufacturer uses software or a website to conduct the undue influence training required by 16 CFR § 1107.24, does a digital signature satisfy the requirement to “sign a statement attesting to participation in such training” under 16 CFR § 1107.24(b)(1)?
Manufacturers are required under 16 CFR § 1107.24(b)(1) to make sure “that every appropriate staff member receive training on avoiding undue influence and sign a statement attesting to participation in such testing.” A digital signature or other electronic attestation (such as a check box) that an employee took the training included as part of software or online training would meet the requirement to “sign a statement attesting.”
This communication has been prepared for general informational purposes only and is based upon the facts and information presented. This communication does not, and is not intended to, constitute legal advice and has not been reviewed or approved by the Commission, and does not necessarily represent their views. Any views expressed in this communication may be changed or superseded by the Commission.