Selling children’s products on Amazon in the United States requires full compliance with the Consumer Product Safety Improvement Act (CPSIA). In this guide, you will learn why Amazon requires CPSIA compliance – and what documents they normally request.
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What is CPSIA?
The purpose of the Consumer Product Safety Improvement Act (CPSIA) is to ensure that children’s products imported and manufactured in the United States are compliant with certain safety standards. Broadly speaking, the standards cover the following:
- Chemicals and heavy metals
- Physical/mechanical properties (e.g. sharp edges and small parts)
- Warning texts
At its core, CPSIA establishes a set procedure which importers and manufacturers must follow in order to ensure compliance. These procedures include the following:
1. Book lab testing with a CPSC accepted testing company
2. Obtain lab test report (which serves as evidence proving that your product is compliant with the relevant safety standards)
3. Create a tracking label file (and possibly also other warning label files) and apply it to the product and its packaging
4. Create a Children’s Product Certificate (CPC) based on the test result
The test report and CPC in particular are used to demonstrate to outside parties that you have ensured CPSIA compliance for your products.
Do Amazon sellers need to ensure CPSIA compliance?
Amazon generally requires sellers to ensure that their products are compliant with all applicable safety standards and other compliance requirements in the country they sell. As such, if you do sell children’s products on Amazon.com in (or to consumers in) the United States you must therefore demonstrate CPSIA compliance.
How do I know if Amazon requires CPSIA documents?
Amazon can require CPSIA documentation (e.g. lab test report and the CPC) either when listing a new product – or request documentation for an existing product listing. We have received reports of cases in which Amazon has taken down products months or even years after the initial listing.
You should always assume that Amazon will at some point request CPSIA documentation if you sell children’s products in the United States.
Amazon CPSIA Document Request Example
Upon investigation, please be informed that your listing has been removed by our internal team due to product safety reasons where the team within Amazon that reviews existing ASINs for compliance with:
1) applicable laws for the marketplace where a product is sold.
2) Children’s Product Certificate (CPC) for the ASINs you are applying to sell
3) Test reports from a CPSC-accepted testing laboratory confirming each product was tested to the requirements listed below:
Please be informed this item has been suppressed due to an ongoing safety investigation. In order to relist your product, contact the manufacturer or brand owner for applicable product safety testing and compliance documents.
Why does Amazon require lab test reports?
Mainly because third-party lab testing is mandatory for all products covered by CPSIA. However, Amazon also requires test reports for the sake of verifying that the product is compliant.
Keep in mind that Amazon does not accept CPSIA test reports at face value. Their compliance team does have a closer look and tend to check the following:
1. Is the product name/SKU matching?
2. Does the test report cover all applicable standards?
3. Is the test report up to date? (e.g. valid for this batch of product)
4. Is the test report issued by a CPSC accepted lab?
A typical mistake made by Amazon sellers is to submit test reports (often provided by the supplier) that are either outdated, fake, or valid for an entirely different product.
Can I get my product CPSIA tested after Amazon requests a test report?
In theory yes, but it’s a very bad idea. Amazon only gives you around 30 days to submit a valid test report. It’s not certain that you can actually get hold of batch samples, and complete the testing process at the lab in that time frame.
You also run the risk of testing failure. If you have ignored all CPSIA requirements until the point that you have actually paid your supplier in full and arranged a shipment to Amazon – the risk is fairly big that your product is inherently non-compliant.
In other words, it may contain restricted substances (e.g. Phthalates or lead) or be inherently non-compliant by design (e.g. contain small parts).
Why does Amazon require a Children’s Product Certificate?
Again, Amazon reflects the official compliance requirements for most products and the Children’s Product Certificate is mandatory for all children’s products sold in the United States. The CPC is not something Amazon made up.
The Children’s Product Certificate is self-issued based on the test report and includes the following information:
1. Product name and description
2. List of applied and mandatory ASTM and CPSC standards (e.g ASTM F963)
3. Importer information (US company name, US address, e-mail, phone)
4. Contact information of the person with access to the test report (name, address, e-mail, phone)
5. Manufacturing location (city, province, country) and date (month, year)
6. Testing date (month, year) and location (city, province, country)
7. CPSC accepted third-party lab testing company (company, contact person, address, phone, e-mail)
Keep in mind that the CPC is not a substitute for a replacement for an actual test report. Further, you will need to create your own CPC. Do not count on your overseas manufacturer to do so for you.
Does Amazon verify compliance with CPSIA labeling requirements?
We have received reports from some sellers stating that Amazon requests photocopies. In the context of CPSIA they are likely mostly interested in product photos showing the following:
- CPSIA tracking label
- Warning labels
Keep in mind that you may need to include the labels on both the product and its packaging.
I highly recommend that you arrange product and packaging photos before shipment as you cannot expect Amazon to do so for you.
What can happen if we fail to submit CPSIA documentation?
Failing to provide the required documentation by the set deadline means that you will not be able to list the concerned product. There are no ways around the CPSIA requirements for Amazon sellers.