CPSIA for handmade children's products: limits, testing and certificates

What the CPSIA is and who it covers

The Consumer Product Safety Improvement Act (CPSIA) amended the Consumer Product Safety Act in 2008. The U.S. Consumer Product Safety Commission (CPSC) enforces it. Most of its rules apply to children's products, which the law defines as products designed or intended primarily for children 12 years of age or younger.

For a CPSIA-compliant children's product, the law generally requires that it comply with the children's product safety rules, be tested by a CPSC-accepted laboratory, have a written Children's Product Certificate and carry permanent tracking information. Those four duties apply to a one-person studio the same way they apply to a factory. The size of the business changes how you prove compliance, not whether the rules apply.

Whether a product counts as a children's product depends on who it is designed and intended for. The CPSC looks at the maker's own statement or label about intended use, how the packaging and advertising present it, whether buyers commonly see it as a children's item, and its Age Determination Guidelines. Baby clothes, plush toys and kids' bracelets are clear cases. A product made for adults is a general-use product, and it needs a General Certificate of Conformity only if a CPSC rule applies to it.

This page is general information about a federal law, not legal advice. States can add their own rules on top of the CPSIA, for example California's Prop 65 warnings, and rules vary by state. Check the rules where you sell and talk to a lawyer about your own products.

Lead and phthalate limits for children's products

The limits a handmade maker meets most often are the lead and phthalate limits. They apply to the finished product as the buyer receives it, including buttons, snaps, zippers, beads, clasps, paint and plastic parts.

Some materials are exempt from testing. For example, the phthalate rule exempts untreated and unfinished fibers from testing. The limit still applies: a testing exemption does not exempt the product from the limit, and you still list the rule on your certificate.

Lead and phthalates are not the only children's product safety rules. Others on the CPSC's list, such as the toy standard and the clothing and sleepwear rules, appear in the small batch section below, and the CPSC keeps the full list of rules that need third-party testing.

Small batch relief: who qualifies and what it covers

The CPSC's small batch program reduces third-party testing for qualifying businesses. To qualify, a business must have gross revenue from all consumer products in the prior calendar year of $1,436,864 or less, the figure given on the CPSC's small batch FAQ, and the product must have no more than 7,500 units made in the previous calendar year.

A business that qualifies registers with the Small Batch Manufacturers Registry on SaferProducts.gov. Registration is required every calendar year. The registry publishes the business name, city and state unless you file a written confidentiality claim within 15 calendar days of registering.

Small batch status splits the rules into two groups. Group A rules are always third-party tested at a CPSC-accepted laboratory, even for small batch makers. Group A covers lead in paint and surface coatings, durable infant or toddler products, pacifiers, small parts, lead in children's metal jewelry, and baby bouncers, walkers and jumpers. Group B is any safety rule not listed under Group A, including total lead content, phthalates, toys (ASTM F963), wearing apparel flammability and children's sleepwear.

• For Group B rules, a registered small batch maker can prove compliance by first-party testing, a non-CPSC-accepted laboratory or a supplier's written assurance.
• The relief is not an exemption to any applicable requirements: the product must still meet every limit.
• A small batch maker must always certify its products in a Children's Product Certificate.

For a maker of baby clothes, kids' jewelry or toys, this matters most for paint and metal jewelry. Painted wooden toys need third-party testing for lead in paint, and children's metal jewelry needs third-party testing for lead, whatever the batch size.

CPSC certificates: the CPC versus the general certificate of conformity

When people search for a CPSC certificate, they usually mean one of two documents. Neither is issued by the CPSC. The business that makes or imports the product writes it and stands behind it.

The Children's Product Certificate (CPC) is issued by domestic manufacturers and importers of children's products. It has no set template, only 7 required elements, and it must be written in English. The General Certificate of Conformity (GCC) covers general-use products that are subject to a CPSC rule. The CPSC's own GCC examples include a mattress.

The seven elements are the product description, each safety rule it is certified to, the maker's name and contact details, the person who keeps the test records, the date and place of manufacture, the date and place of testing, and the lab. If a product is exempt from testing for a rule, you still issue a CPC, citing the rule and the exemption claimed. Importers should also know that from July 8, 2026, most certificates for imported regulated products are filed electronically with U.S. Customs and Border Protection.

CPSIA tracking labels on the product and its packaging

Every children's product needs a tracking label that is permanently affixed to the product and its packaging, to the extent practicable. The label lets a buyer, a store or the CPSC trace a product back to a batch if there is a recall.

The label must make it possible to find the manufacturer or private labeler name, the location and date of production, and batch or run information. The information may be in code form, as long as the buyer knows who to contact to read the code. Tracking labels are a separate duty from testing: the CPC does not need to include a reference to tracking labels.

• Example for clothing: a sewn-in label with your business name, the city and state, and a batch code such as the month and year of the run.
• Example for toys: a sewn-in tag on plush toys, or a stamp or engraving on wood, plus the same details on the hang tag or box.
• Example for jewelry: where the piece is too small to mark, put the details on the card, box or bag it ships in.

How to get a handmade children's product CPSIA compliant

Work through these steps for each product before you list it. Keep the records together, because a store or the CPSC can ask for them.

1. Decide whether it is a children's product

   Ask whether the product is designed or intended for children designed or intended primarily for children 12 years of age or younger. If it is not, check whether a CPSC rule applies to it as a general-use product, which would need a GCC.

2. List the rules that apply

   Use the CPSC's list of children's product safety rules. For handmade clothing, toys and jewelry, the rules that come up most are among total lead content, phthalates, toys (ASTM F963), wearing apparel flammability and children's sleepwear, plus lead in paint where there is a coating and lead in children's metal jewelry.

3. Register as a small batch manufacturer if you qualify

   If your revenue is $1,436,864 or less and the product is no more than 7,500 units a year, register for the calendar year. Then decide, rule by rule, which Group B rules you can cover with supplier assurances or your own testing.

4. Send Group A items to a CPSC-accepted lab

   Paint and coatings, children's metal jewelry, small parts and the other Group A rules are always third-party tested at a CPSC-accepted laboratory. The CPSC's lab search lists accepted labs.

5. Write the Children's Product Certificate

   Include all 7 required elements. Put your small batch registration number in the lab section where you rely on it, and list any testing exemption you claim.

6. Add tracking labels and keep the file

   Mark the product and the packaging, then keep the CPC, test reports and supplier documents together, so you can produce the CPC within 24 hours when CPSC or Customs asks.

Where Nation fits

Questions about CPSIA compliance