Initial Certification Testing

All children's product require initial certification testing to show compliance with applicable children's product safety requirements.

All children's products must be third party tested by a CPSC-accepted laboratory for compliance with applicable children's product safety requirements before the product is sold in the United States.


What is Initial Certification Testing?

The first time a children’s product is tested for compliance with children’s product safety requirements is called initial certification testing. (The regulation calls this “certification testing.”) Based on passing results from the initial certification testing, the manufacturer or importer then must issue a Children's Product Certificate.


Certain children’s products may never require more than initial certification testing, if, for example, the children’s products are produced in limited production runs and with no material changes within each production run. Certain children’s products may require subsequent testing, such as material change testing, periodic testing, or testing of a component part, if necessary. (See the box on the right-hand side of the page forfurther information.)


Who must comply with this requirement?

Importers and U.S. manufacturers are responsible for providing a written Children’s Product Certificate to ensure that the third party testing requirements have been met. The importer must ensure that the children’s product has been tested by a CPSC-accepted laboratory for products manufactured overseas. The U.S. manufacturer must ensure that the children’s product has been tested by a CPSC-accepted laboratory for products manufactured domestically. See 16 C.F.R. part 1110.


How can manufacturers determine which children's product safety requirements are applicable to their children's products?

Manufacturers and importers may view the complete list of requirements for products that require third party testing and certification. Nearly every children's product requires some third party testing to demonstrate compliance with applicable children’s product safety requirements, unless there is an exemption from testing, such as exemptions for some small batch manufacturers or for some materials determined not to contain lead.


What records must a manufacturer maintain?

The law requires a manufacturer to maintain records of all Children’s Product Certificates and of all third party certification test results for 5 years. This records requirement includes test results from initial certification testing, and if applicable, from material change testing, periodic testing, and component part testing. (See the box on the right-hand side of the page for further information.)


Can a manufacturer label a product as meeting applicable federal consumer product safety requirements?

Yes. A manufacturer, importer, or private labeler may include the following statement on a label to a consumer product and/or its packaging: “Meets CPSC Safety Requirements.” The label must be visible and legible.

The label may be added only if the product has been properly certified with a Children’s Product Certificate that the product complies with all applicable consumer product safety rules under the CPSA and with all rules, bans, standards, or regulations applicable to the product under any act enforced by CPSC.

A manufacturer may use a label in addition to the one described above, as long as such label does not alter or mislead consumers about the meaning of the text in the statement above. An importer, manufacturer, or private labeler must not imply that the CPSC has tested, approved, or endorsed the product.


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.