Children’s jewelry products are subject to mandatory safety standards, chemical and heavy metals restrictions, lab testing, certification, and labeling requirements in the United States.
In this guide, we introduce the reader to CPSIA, ASTM standards, substance restrictions, and other requirements applicable to children’s jewelry.
The Consumer Product Safety Improvement Act (CPSIA) sets requirements concerning the safety aspects of children’s products, including children’s jewelry. In particular, CPSIA requires that children’s products must comply with applicable product safety standards, lab testing, documentation, and labeling requirements.
- ASTM F2923
- Children’s Product Certificate (CPC)
- Test Report
- Tracking Label
ASTM F2923 – Standard Specification for Consumer Product Safety for Children’s Jewelry
ASTM F2923 covers children’s jewelry that is intended primarily for children 12 years of age or younger. It also specifies that jewelry is not recommended for children 3 years of age or younger and that are let without close adult supervision.
This standard establishes requirements and test methods for certain chemical and mechanical hazards in children’s jewelry, such as excessive exposure to heavy metals, small magnets hazards, and strangulation hazards. Also, ASTM F2923 covers age labeling and warnings texts.
ASTM F2923 sets out the requirements regarding the toxicological hazards of children’s jewelry. Importers and manufacturers are responsible to verify whether their jewelry contains excessive levels of restricted substances.
Here are some example of the restricted substances and their limitation under this standard:
- Lead: no more than 0.01% by weight
- Cadmium: no more than 0.03% by weight
- Nickel: release rate should not exceed 0.2 μg/cm2/week
ASTM F2923 sets out the mechanical requirements for children’s jewelry. For example, children’s jewelry should not contain hazardous magnetic components unless it is intended for children 8 years of age or older, and it carries a warning statement.
Also, necklaces should be built in a way that the lace breaks when stressed under a certain weight. This feature is designed to avoid strangulation hazards. More in general, importers and manufacturers should ensure that the product design does not potentially cause hazards to children.
ASTM F2923 includes instructions for warning statements, such as minimum age warnings. Importers and manufacturers should identify the potential hazards associated with their jewelry products, and attach a relevant warning label in the product or its packaging.
This standard provides test methods for toxic elements content and certain mechanical hazards in children’s jewelry. For instance, children’s jewelry should be tested for excessive exposure to heavy metal and other substances in the product, paint, or surface coating.
The test methods are also applicable for children’s jewelry intended to be attached around the neck in order to prevent breakaway or similar incidents.
For example, reference test methods 16 CFR 1500.51 and 16 CFR 1500.52 provide the test procedure for simulating the use and abuse of toys and other articles intended for use by children 18 months of age or less.
In this section, we explain the Children’s Product Certificate and test report requirements for children’s jewelry.
Children’s Product Certificate (CPC)
The Children’s Product Certificate (CPC) is a compulsory document created by either the importer or the manufacturer, to declare product compliance under CPSIA. The CPC is often required by US customs, retailers, or even e-commerce platforms such as Amazon.
You should include at least the following information on the CPC:
- Manufacturer or importer’s information
- Lab testing company’s information
- Product description
- List of applicable standards (e.g. ASTM F2923)
- Production date and place
- Testing date and place
- Test reports
The CPSIA requires that children’s products must be tested by a CPSC-accepted laboratory. In addition, importers and manufacturers must obtain a valid test report before importing their children’s jewelry to the US.
You should also ensure that the test reports are valid for your specific products. For example, a test report only applies to the specific product SKUs listed on the report, while you cannot use the same reports for other products. Test reports are also specific to the materials used to manufacture the product, and its colors.
You can find a list of CPSC-accepted testing laboratories on the CPSC’s official website.
CPSIA Tracking Label
The CPSIA requires that importers and manufacturers must attach a visible and legible tracking label to their products. When it is not feasible to bear the label on jewelry, you should include the label on the product packaging instead.
A tracking label should at least display the following information:
- Batch number
- Importer or manufacturer information
- Date of production
- Manufacture location
US State Regulations for Children’s Jewellery
Specific state laws might also apply to your children’s jewelry. Note that state laws might have stricter requirements on heavy metal when compared to federal regulations. In this section, we provide some examples of such laws.
California: Metal-containing Jewelry Law
The Metal-containing Jewelry Law regulates the levels of hazardous metal contained in children’s jewelry. It classifies jewelry material in the following classes:
a. Class 1 – Stainless steel, platinum jewelry
b. Class 2 – Electro Plated or unplated metal jewelry
c. Class 3 – Jewelry that contains less than 0.06% lead by weight
This law restricts the amount of lead and cadmium in children’s jewelry to protect children from heavy metal exposure. The lead and cadmium restrictions are different according to different parts and classes of the jewelry items. For example, children’s jewelry components should not contain more than 0.03% of cadmium by weight. Conversely, the maximum allowed amount of cadmium in the surface coating is 0.0075% by weight.
The Metal-Containing Jewelry law also provides the test methods for determining substance content in children’s jewelry. For example, lab testing companies should use EPA methods 3050B, 3051A, or 3052 to determine compliance with this law.
Connecticut: Children’s Jewelry Containing Cadmium Law
This law sets out the limitation on the amount of cadmium in children’s jewelry that is intended to be worn by children 12 years of age or younger.
For example, any jewelry including bracelets, necklaces, earrings should contain less than 0.0075% of elemental cadmium and any compound that contains cadmium.
Maryland: Cadmium in Children’s Jewelry Law
This law prohibits selling children’s jewelry that contains more than 0.0075% of cadmium by law. It covers jewelry that is intended for children 12 years of age or young.
Country of Origin Label
The Country of Origin label is a mandatory requirement for imported consumer products in the US. Therefore, children’s jewelry importers and manufacturers should also bear a permanent and legible label on the products and/or on the packaging.
The label should inform the customers about the manufacturing country. Here are some examples:
- Made in French
- Made in Thailand
- Made in China
- Made in India
Children’s jewelry Amazon sellers must ensure that their products are compliant with US regulations before listing. In general, Amazon checks product compliance by requiring relevant documentation, which might include the CPC, test reports, photos of the product labels, and other items.
This specific page on the Amazon Seller Central explains how importers and manufacturers should request approval before listing their children’s Jewelry.
Here is an overview of the documentation requirement for Amazon’s sellers:
- Company name
- Seller ID
- Seller’s contact
- A list of ASINs
- Product image and manuals
- Children’s Product Certificate
- Test reports
More specifically, Amazon requires that children’s jewelry must be tested in accordance with ASTM F2923-14, and a small parts warning, when applicable.
Children’s jewelry manufactured outside the United States may contain excessive amounts of restricted substances. Such substances include, for example, phthalates, lead, mercury, and cadmium. It’s therefore critical to verify product compliance before importing children’s jewelry to the USA – which can only be done through third-party lab testing. As mentioned, third-party lab testing is also mandatory under CPSIA.