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Testing according to referenced ASTM standards, which includes ASTM F963-23, is mandatory when importing and manufacturing children’s products in the United States. In this guide, we answer essential questions that you may have about CPSIA lab testing requirements and ASTM F963-23 testing in particular.
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What is CPSIA lab testing?
The Consumer Product Safety Improvement Act (CPSIA) applies to all children’s products for children aged 12 years or younger. The CPSIA requires all such products to be tested by a third-party testing company accepted by the Consumer Product Safety Commission (CPSC).
That said, the CPSIA is not a safety standard but references other standards. This includes, for example, ASTM F963-23 – Standard Consumer Safety Specification for Toy Safety.
ASTM F963 and other relevant standards cover various aspects of product safety:
- Substance restrictions: Lead, mercury, and other chemicals and heavy metals
- Physical properties: Sharp points, loose parts, small parts, etc
- Flammability
Further, some testing requirements under the CPSIA are based on CPSC rules rather than ASTM standards.
The purpose of CPSIA lab testing is to verify that your product is technically compliant with CPSIA, and you will receive a test report used to prove this.
What are some other ASTM standards and rules that may apply?
Different ASTM standards apply depending on the product. While ASTM F963 is the standard most commonly included in a CPSIA testing process, it’s not the only one to keep track of.
Here are a few other examples of ASTM standards and rules applicable to various types of children’s products:
ASTM F2923 – Standard Specification for Consumer Product Safety for Children’s Jewelry
ASTM F2236: Standard Consumer Safety Specification for Soft Infant and Toddler Carriers
ASTM F2923-14, CSPA Phthalates & Cadmium, and Small Parts Warning
16 CFR Part 1511 – Requirements for Pacifiers
16 CFR Part 1303 – Ban Of Lead-Containing Paint and Similar Surface Coatings
16 CFR Part 1500.87 – Children’s products containing lead: inaccessible component parts
How do I know which ASTM standards apply to our product?
In many cases, more than one ASTM standard or other standard applies to a product. Further, standards may not always apply in their entirety – but only apply to a certain extent.
Examples
- ASTM F963 – Toys-Mechanical Hazards
- ASTM F963 – Toys-Flammability of Solids
- ASTM F963 – Toys-Soluble Heavy Metals Content
- CPSIA Section 101-Children’s Products-Total Lead (Pb) Content
The good thing is that you as an importer don’t need to make this assessment yourself. Instead, you can ask a CPSC-accepted lab testing company such as QIMA or TUV Rheinland for a quotation, in which case they always present their assessment (e.g. a list of ASTM standards, parts, and substance restrictions).
How do I make sure that my product is ASTM F963-23 compliant in the first place?
You can buy ASTM F963-23 and other relevant ASTM standards on www.astm.org. The standards can be accessed as PDF files which you can then review to better understand their respective technical requirements.
These requirements must then be implemented into your product design, to ensure that your product design is not inherently non-compliant.
Is CPSIA lab testing mandatory?
Yes, the CPSIA requires that all toys and other children’s products imported and sold in the United States are lab tested by a CPSC-accepted third-party testing company. Here are some examples of companies that operate facilities listed as CPSC-accepted:
- QIMA
- Eurofins
- Intertek
- SGS
- Bureau Veritas
- TÜV Rheinland
- Underwriter Laboratories (UL)
- TÜV SÜD
- DEKRA
Further, the lab test must be conducted on products originating from the same product run (e.g. batch) as those you place on the market.
What are CPSC-accepted labs?
CPSC-accepted labs are third-party testing companies that are accepted by the U.S. Consumer Product Safety Commission (CPSC). This means that only CPSC-accepted labs can issue valid test reports, that demonstrate compliance with CPSIA requirements and referenced standards – such as ASTM F963-23.
The test report is also the basis for the Children’s Product Certificate (CPC).
Notice that CPSC-accepted labs are not covered for all possible children’s products. Instead, their accreditation is only valid for certain product types.
Do I need to get the lab test done in the United States?
No, you don’t necessarily need to get your product ASTM and CPSIA tested inside the United States. However, the lab must be accepted by the CPSC for the test report to be valid. If not, you’re just wasting your money.
Can I have the product tested in China?
Yes, as long as the lab is CPSC-accepted. Essentially all major American and European testing companies operate CPSC-accepted facilities in China. Examples include UL, SGS, Intertek, and TUV Rheinland.
China is possibly the leading exporter of toys and children’s products, which is why many US importers choose to have their products tested there. Working with a lab in the same country as your factory makes it faster and more affordable to deliver samples.
Can I use a test report from my supplier?
You can normally not use a test report issued by your supplier for the following reasons:
1. The test report must be valid for the same production lot or batch that you import and sell in the United States. As such, pre-existing test reports valid for previous production runs cannot be applied to your product batch – even if it’s the same product, material, and supplier.
2. The test report company name must match your company name, as you also need to issue a Children’s Product Certificate. A test report issued in your supplier’s name cannot fulfill that requirement.
Some importers make the mistake of using old and outdated lab test reports provided by their suppliers – sometimes not even applicable to the same product.
At what stage should we book CPSIA lab testing?
The lab test must be performed on a product that represents the product you sell in the US. Hence, you must collect samples from a mass-produced batch of items rather than pre-production samples or prototypes.
That being said, lab testing pre-production samples according to applicable ASTM standards and other CPSIA requirements is often a good practice – for the sake of verifying that the design of your product is inherently compliant.
Some brands do partial CPSIA testing for this reason, which is followed up with a “final” CPSIA lab test before shipment.
The last thing you want to do is enter mass production based on a design that is destined to fail CPSIA lab testing due to built-in design flaws.
Do I need to test all the products?
Yes, you need to test each SKU (e.g. product design or model) that you import and sell in the United States. This also applies to different variations of the same product, such as products with different dimensions, materials, or colors.
As such, you need to ensure that each variation of your products is lab tested. This also makes CPSIA compliance testing more expensive, as lab tests must be repeated. That said, there is no way around this.
Do I need to test my products each time we place an order?
While you don’t necessarily have to test every single order you must get the first production run tested. Further, you must also create a testing plan that takes the following into consideration:
1. Testing routine in case a product fails the lab test
2. Standard testing frequency (in case of no failed lab tests)
In short, you cannot rely on a single test report forever. The CPSC guidelines also recommend that importers who lack insight into the manufacturing process and material procurement get every single production run lab tested.
What happens if our product fails CPSIA lab testing?
In that case, you cannot sell the product. Your next course of action is to investigate what went wrong, and make adjustments. This can consist of the following:
1. Replace non-compliant materials and components
2. Adjust product design
However, it is often not technically and economically viable to make changes. For example, if it turns out that the fabric of a baby romper contains excessive amounts of lead, then the product cannot be made to comply. Likewise, a molded plastic toy that contains small parts is inherently non-compliant by design.
As such, remaking the product is the only option.
Does Amazon require CPSIA test reports?
Yes, Amazon is strict when it comes to verifying that toys and other children’s products sold on their US marketplace are fully compliant with CPSIA. Amazon normally requires that you submit your CPSIA lab test report, together with your Children’s Product Certificate (CPC).
Further, Amazon also requires that the ASTM standards listed on the test report match those listed on the CPC.
The company name listed on the test report must also match that of the CPC.
Do I need to get my product tested if it’s already sold in the United States?
It doesn’t matter if “the same” or “similar products” are currently sold in the United States – even if these originate from the same manufacturer (which is unlikely). It’s by definition not “the same product” unless it’s an item from the same batch.
There can be differences in terms of construction and materials even if these “similar products” are of the same model and original manufacturer. These are factors that can impact the general safety and substance contents of the product – both of which ultimately decide whether the product is CPSIA compliant or not.
Yet, some importers assume that they can skip CPSIA lab testing simply because other companies are selling comparable products. That’s not how it works.
What should I do with the lab test report?
You need the lab test report to issue a Children’s Product Certificate (CPC), which is mandatory as part of the CPSIA compliance process.
Further, the customs authorities, CPSC, or even Amazon may require your lab test report at some point in the future to verify compliance with all applicable ASTM standards and CPSIA rules.
How to manage your lab test booking
Step 1: Find a CPSC-accepted testing company
Only a test report issued by a CPSC-accepted testing company is valid. As such, you must identify one from the CPSC-accepted third parties list.
At this stage, you should also request a quotation. They will most likely ask you to provide the following:
- Product description
- Bill of materials
- Product photos
- Manufacturing country
- Age group
Step 2: Submit product samples to the lab
You can either submit product samples yourself, instruct your supplier to do so, or send an inspector to collect samples. What really matters is that the sample is collected from the same production run as the products you import and sell in the United States.
The only way to be sure is by either sending the samples yourself or sending a third-party inspector to collect for you – preferably the same person who carries out your pre-shipment quality inspection.
In most cases, you need to send at least 3 to 4 product samples, as the testing company needs a certain amount of materials.
Step 3: Confirm quotation
The testing company will send a final quotation once they’ve received the product samples. It can look something like this:
| Overview | Cost (USD) |
| ASTM F963-23-Toys-Mechanical Hazards | 100 |
| ASTM F963-23-Toys-Flammability of Solids | 120 |
| ASTM F963-23-Toys-Soluble Heavy Metals Content | 120 |
| CPSIA Section 101-Children’s Products-Total Lead (Pb) Content | 140 |
| Total cost (US Dollars) | 480 |
Step 4: Receive test report
Once the test is done, which normally takes around a week, you will receive a test report. This document is then used as an attachment to your Children’s Product Certificate (CPC).
CPSIA lab testing costs
The testing costs depend on these factors:
- Product type and design
- Number of products
- Number of applicable ASTM standards
- Number of materials
- Number of colors
The total testing cost, per product, varies from $200 to $1500.
Example A: Blue T-Shirt
A single product made of one material, in one color, is therefore not that expensive to test.
| Overview | # Tests | Cost (USD) |
| ASTM F963-23-Toys-Mechanical Hazards | 1 | 80 |
| ASTM F963-23-Toys-Flammability of Solids | 1 | 120 |
| ASTM F963-23-Toys-Soluble Heavy Metals Content | 1 | 50 |
| CPSIA Section 101-Children’s Products-Total Lead (Pb) Content | 1 | 100 |
| Total cost (US Dollars) | 350 | |
Example B: Plastic Toys
However, the calculation is different if you intend to sell plastic toys in 4 different colors.
| Overview | # Tests | Cost (USD) |
| ASTM F963-23-Toys-Mechanical Hazards | 4 | 50 |
| ASTM F963-23-Toys-Flammability of Solids | 4 | 50 |
| ASTM F963-23-Toys-Soluble Heavy Metals Content | 4 | 50 |
| CPSIA Section 101-Children’s Products-Total Lead (Pb) Content | 4 | 150 |
| Total cost (US Dollars) | 1000 | |
How to reduce your testing costs
The best way to reduce your testing costs is by limiting the number of materials and colors. If you’re starting a new business, you should also consider limiting the number of products you launch with, as testing is required for each SKU.
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Hello Fredrick, thanks for your video and comprehensive explanation. I intend to sell on Amazon a plush toy. In this case, do you know if is required/mandatory to get the uniform label register number required by the state of Pennsylvania, Ohio and Massachusetts? Kind regards
If sale blue shirt with various colored print will they test just blue shirt or do they include the print?
Hi Shannon,
The print should normally be included in the testing process as well.
Hello,
I am a disabled guy that makes a few wooden toys how to I get a CPC. Thanks for your help
Hello Brian,
I suggest you read this:
https://www.cpsc.gov/Business–Manufacturing/Small-Business-Resources/Small-Batch-Manufacturers-and-Third-Party-
Hi Fredrik,
We have tracking label on all products, and all products tested accordingly.
We put: “Meets ASTM F963” in writing on packaging, but can we just cancel this? – as we are having space problems on the packaging…
Hi Eddy, Great video. You mentioned getting the batch number tested before it’s shipped. So are you saying for example ..pay the factory for the batch to be produced. Have a CPSIA approved lab in China take random samples from the batch before sending? Also, would it be normal to send to the USA without testing, but then have it tested once in USA?
Hi Fraz,
It would be very risky to send to the US without testing. For starters, I think the CPSC requires that you have a test report upon entry. Even if that was not required, you would risk finding that the batch is non-compliant when it’s too late to do anything about it!
I have a product that I am manufacturing in Thailand and I need ASTM/CPSC tests done. Do you do the testing or can you recommend a company that does.
Hi Nick,
You can find a list here: https://www.cpsc.gov/cgi-bin/labsearch/
Hello Fredrick,
I bought 1000 set of wooden alpha numeric puzzle in 2019 to sell in amazon but now amazon blocked this product asking for
“ A third-party test report from a CPSC-accepted lab that shows the product meets ASTM F963-16/17 and CPSIA standards.” How do I get this report? Can I test this from United State? Please let me know.
Thank you
Sujan
You need to book a lab test with a CPSC accepted testing company. You will also need to issue a CPC and ensure that the products are correctly labeled.
I am manufacturing a product an understand that it must undergone Third-party testing to verify that it conforms to a certain ASTM/CPSC standard. I also understand that each product style must be tested from each batch production. Does that mean that I’ll produce in bulk, then get it tested? If it doesn’t pass for whatever reason I have a bulk order that doesn’t comply. Can you please confirm that is the expected process?
Hi Lucy,
1. Yes, I think CPSIA requires batch testing (e.g. sample from the mass-produced batch)
2. Well, you may want to also test pre-production samples made using the same material and a 100% matching design/construction to verify compliance before you start your first production run
Hi Fredrik,
if i am looking to create a toy bundle to be sold on Amazon, and the toys within the bundle are manufactured by different suppliers in China(eg. one is a wooden toy, the other is a kids costume to be included in the bundle) – based on your knowledge, how should this be tested? (send the complete product bundle to the testing lab or do they need to be tested separately? since one is a wooden toy and the other is a costume). Thanks mate, cheers.
Hi Jack,
Personally, I would try to get it on the same test report – or at least test reports issued by the same company on the same date.
Hi Fredrik,
For sports equipment like Hockey sticks, Would flammability testing be required?
Hi Ahmed,
You need to ask a lab
Hello Fredrik Gronkvist
I’m interested in testing product is kid shirt
according to standard ASTM F963 16/17 and standard CPSIA
I’m not sure that what is full standard of testing CPSIA for kid shirt ?
Dear Mr. Fredrik
This is Mr. Park who is working for 3rd party testing lab in Korea.
I was wondering if we need to get textile parts of stuffed toys tested for heavy metals(8 elements). I am confused because it is not metal parts.
Have a nice weekend.
Thank you
Hi Doeui,
Heavy metals are not only found in metal parts.
Hi Mr. Fredrik,
A Korean manufacturer want to sell stickers for kids through AMAZON.
I was wandering if the stickers are subject to toy products.
Thank you
Hello Doeui,
Yes. I suggest you read this: https://www.cpsc.gov/Business–Manufacturing/Business-Education/childrens-products
Do children’s pajamas require physical and mechanical testing?
Hi Ben,
You need to ask that directly to a lab.
My toy product have ASTM F963-16 and CPSC approved test.
Do i need ASTM F963-17 test although the revisions are not influence my toy?
Hi Yossi,
Only a lab can confirm that
Hello Yossi, I just saw your question when I was browsing the internet and I wanted to answer it. You will need to retest your products to the new standards. In fact, the US Federal Law requires your products to be tested yearly unless you have a documented and executed Testing Plan. Roger at AMTesting
Thank you for the information.
Can you please advise with the following:
Am I required to place a label on all my plush animals I am manufacturing in order to sell them? As in the one that state’s CE? Or will the lab test documents sent to Amazon be sufficient.
Hi Natalie,
Assuming you sell in the US you’ll need a CPSIA tracking label: https://www.cpsc.gov/Business–Manufacturing/Business-Education/tracking-label
Hello Frederik,
Got to start by thanking you for this informative article. I am about to launch my new all-wooden toy (contains water-based paint in different colors) on Amazon and I am a little confused with all this terminology. Would the CPSIA test differ from ASTM F963? When asking for a quote for ASTM F963, would that quote already include the CPSIA certification automatically or should I be concerned about looking for two different tests? My supplier seemed kind of unaware about the CPSIA when I brought it up to our conversation as they already gave me a specific quote for ASTM F963 of $621.00.
Hi Jorge,
CPSIA references certain ASTM standards, such as F963. CPSIA is more than ASTM compliance and testing though, as it also covers labeling and the CPC.
No, most testing companies don’t include the CPC or tracking label as part of the quote.
Hi,
When amazon is asking for manufacturer name and address are they wanting mine as the amazon seller or the manufacturer in China’s name and address ?
Likely you as the Amazon seller
hey, my product is a desk toy box, i mainly target offices but have marketed to kids….can i just change my minimum age to 15 to avoid all this?
Hi Alan,
I don’t think so.
This is one definition according to the CPSIA:
“- Whether the product is commonly recognized by consumers as being intended for use by a child 12 years of age or younger. ”
https://www.cpsc.gov/Business–Manufacturing/Business-Education/childrens-products
Your statement : No, you cannot use a test report issued by your supplier does not agree with what the CPSIA website states.
CPSIA website … “…allows importers to use a foreign manufacturer’s test results or their component part or finished product certifications of a children’s product to issue their own Children’s Product Certificate, as long as the importer exercises due care to ensure the validity of the test results or the certificate and receives the documentation required by the rule.”
https://www.cpsc.gov/Business–Manufacturing/Testing-Certification/Third-Party-Testing/FAQs-Certification-and-Third-Party-Testing
Also, your statement “The test report company name must also match your company name, as you also need to issue a Children’s Product Certificate. A test report issued in your supplier’s name cannot fulfill that criterion.”
Can you please provide to source to this? Because if the test report is in the manufacturer’s name, but the CPC is in YOUR company’s name, these names don’t match. But that shouldn’t be an issue?
Unless Amazon’s stipulations differ from the CPSIA stipulations (are more strict), than I’m confused as to where the two above stated stipulations are from? Please let me know, as I am an Amazon toy seller!
Hello Kristina,
1. Theory and practice are different. This only works if there is a pre-existing lab test report for that same batch, which simply doesn’t happen for small businesses.
2. Amazon can reject test reports and CPCs not matching for many reasons. Any mismatch in the listed tests, SKU, or company can result in that.
For a plastic toys, we want to make sure our toys were tested and made sure it non toxic, bpa free, phthalate free and lead free.
Would you mind giving us a quote for that specific test?
1 – CPSIA (15 USC 1278a) – Lead in accessible substrate materials
2 – CPSIA (16 CFR 1307) – Phthalates
3 – 4.3.5.2 (ASTM F963-17), Toy Substrate Materials – Total Lead & Soluble Test for Metals
4 – 4.2 (ASTM F963-17), Flammability
5 – ASTM F963-17, Mechanical and physical properties?
Hi She,
You can request a free quote here: https://www.compliancegate.com/lab-testing/
Hi Fredrik, thank you for sharing this informative article. I try to get my head around US guidelines for toy testing, and a lot of information I have been reading might have been outdated? Is it correct that toy testing in the US was voluntary previously? Since when is it Mandatory for the US for toys to be tested by a third party?
During my research, my understanding is that Australia has mandatory toy testing but this can be either done in house or external.
I am looking forwards to your response.
Kind regards Jude
Hi Jude,
I have no idea if it was voluntary before CPSIA.
Hi Fredrik
Do I need to formally identify every product sample SKU to the Lab? For example when the samples are delivered do i tell them in a note: included is SKU1, SKU2 etc? Do they include this in the lab report or do they just use a general description of the item?
many thanks, very useful!
Hi Andrey,
Glad you found it useful!
I am looking to sell and donate to charity wooden toys. I understand that it has to be CPSC certified however, I am individual not a company or make enough to be a small batch person. Is there any certification that and individual that would possibly make one to two hundred to sell and donate? They would be toy cars, wood would be maple, pine, purple heart or combination, Titebond II wood glue for adhesive and mineral oil finish (food safe). I have gone through the CPSC numerous times and have not found anything that addresses individuals.
Hi Stephen,
I don’t think individuals are exempt. You must still ensure that the products you import are safe and compliant. There are some testing exemptions, but the fundamental safety requirements are the same. Third-party testing is the only way to verify if a product conforms to a certain ASTM/CPSC standard.