• CPSIA Children’s Product Certificate (CPC): A Practical Guide

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    Planning to import toys and children’s products to the United States or sell on Amazon? If so, a Children’s Product Certificate (CPC) is mandatory. In this guide, we explain why you need a CPC, how to create on and why you should not rely on your overseas manufacturer to do it for you.

    What is a Children’s Product Certificate?

    A Children’s Product Certificate (CPC) is a document issued by the importer or manufacturer, certifying that the product is compliant with all CPSIA requirements.

    The CPC is provided upon request to the US customs, retailers, the CPSC, state authorities or e-commerce market places such as Amazon.com.

    Why do I need a Children’s Product Certificate?

    The CPC is mandatory when importing and selling all children’s products. Here are a few examples of what can happen without a CPC:

    • Products seized by the US customs
    • Freight forwarders may refuse to ship your products
    • The CPSC may issue a forced recall
    • Amazon may refuse to list your product

    You also need a test report to complement each CPC.

    Toy manufacturer

    Which products require a CPC?

    The CPC is mandatory for all products covered by the Consumer Product Safety Improvement Act (CPSIA). Broadly speaking, the CPSIA is applicable to all toys and children’s products sold in the United States.

    1. If the product is marketed as appropriate for use by children of 12 years old or younger

    2. If the product packaging presents the product as appropriate for use by children of 12 years old or younger

    3. If the product display (e.g. sold in a toy store or online store selling children’s products) presents the product as appropriate for use by children of 12 years old or younger

    4. If the product is generally recognized as a product primarily intended for use by children of 12 years or younger

    As such, any product that may remotely be considered a children’s product is therefore covered by the CPSIA – which means that you must issue a Children’s Product Certificate.

    Here are a few examples:

    • Plastic toys
    • Plush toys
    • Dolls
    • Children’s clothing
    • Baby products
    • Children’s furniture
    • Children’s Accessories
    • Children’s Jewellery
    • Toy vehicles
    • Wooden toys
    • ATVs

    Do I need to create a CPC for each product?

    Yes, you need to issue a CPC for each product. That said, you can have more than one color variation. Further, you must also hold a test report for each product (including colors) listed on the CPC.

    Do I need to create a CPC for each new order?

    You don’t necessarily have to issue a new CPC each time you place an order. However, you must issue a new CPC in any of the following situations:

    • You import a new product for the first time
    • You import a new version of an existing product (e.g. new color, design or material)
    • You change supplier or production facility
    • You get the product re-tested

    What information do I need to include in the CPC?

    Here is an overview of the information you must include in the CPC:

    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)

    Who is responsible for issuing the Children’s Product Certificate?

    The CPC must either be issued by the US importer or the domestic manufacturer. Note that the latter only applies in case the product is manufactured in the United States. Importers are therefore responsible for creating the CPC for products manufactured overseas.

    Can foreign (non-US) companies issue a CPC?

    The CPC should include the details of the US company importing or manufacturing the product.

    The CPSC may also accept that you list the name of a US Importer of Record on the CPC. For example, this could be a customs broker or other agent – with their permission. That said, Amazon and retailers may or may not accept this.

    Can I get a CPC from my supplier?

    The CPC should include the details of either the US company importing the product, or manufacturing the products inside the country. As such, the CPC should not be issued by suppliers outside the USA, for example in China or Vietnam.

    Do I need to get the CPC approved by a third party?

    No, the CPC is not approved by CPSC or any other party. However, the CPC must list all ASTM and CPSC standards to which the product conforms. Further, you must also hold a test report corresponding to the listed ASTM and CPSC standards.

    Finally, that test report must be issued by a CPSC approved third-party testing company. Otherwise, the test report is not valid, which means that your CPC is not valid either.

    How much does a Children’s Product Certificate cost?

    Nothing. At least not more than it’ll cost you to print the paper it’s written on. The CPC is a self-issued document, not a permit or a license you buy from the government or any third party.

    That said, the CPC is based on the test report. That test report can cost anything from a few hundred to thousands of dollars, depending on the number of materials, components, and colors.

    Does Amazon require a Children’s Product Certificate?

    Yes, Amazon requires that you can provide a CPC when listing children’s products for sale in the United States. WIthout a CPC, Amazon can reject new product listings or suspend existing product listings.

    Further, Amazon is also strict when it comes to certain details on the CPC.

    For example, Amazon requires that the ASTM and CPSC standards listed on the CPC correspond to the ASTM and CPC standards mentioned in the test report.

    I’ve seen cases when Amazon outright rejects CPCs because of a standard or regulation listed on the test report is missing – and vice versa.

    Children’s Product Certificate (CPC) Sample

    Identification of the product covered by this certificate:

    Wooden Toy A01, Red, White and Blue.

    Citation to each CPSC product safety regulation to which this product is being certified:

    ASTM F963-17-Toys-Mechanical Hazards
    ASTM F963-17-Toys-Flammability of Solids
    CPSIA Section 101-Children’s Products-Total Lead (Pb) Content

    Identification of the importer or domestic manufacturer certifying compliance of the product:

    Wooden Toys LA LLC
    9015 Sunset Blvd
    Los Angeles, California
    United States

    Contact information for the individual maintaining records of test results:

    Axl Rose
    Wooden Toys LA LLC
    9015 Sunset Blvd
    Los Angeles, California
    United States
    (+1)1234567890

    Date and place where this product was manufactured:

    June 2020, District 9, Ho Chi Minh City, Vietnam

    Date and place where this product was tested for compliance with the regulation(s) cited above:

    August 2020, Kowloon, Hong Kong S.A.R (China)

    Identify the third party, CPSC-accepted where this product was tested by an accredited laboratory (accepted by the CPSC) for compliance with the regulation(s) cited above:

    Hong Kong Lab Center Kowloon
    Saigon Street 119
    FL 5, Mongkok Building
    Kowloon, Hong Kong S.A.R (China)
    [email protected]
    +852-1234567890

    You can find CPC templates on the CPSC website.

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  • 45 Responses to “CPSIA Children’s Product Certificate (CPC): A Practical Guide

    1. gel at 11:44 am

      HI! i was wondering if Amazon will accept CPC even if my business is not registered? Is it mandatory for business to be registered for Amazon to accept CPC of a product?thanks

      1. Fredrik Gronkvist at 10:09 am

        Hi Gel,

        I think they (the CPSC) state that it must be issued by an importer or US domestic manufacturer. I don’t know if an individual can be an importer in this context. You would need to contact a lawyer I think.

    2. Michelle at 12:05 am

      Hello, Frederik

      Glad to come across your article. I sell on Amazon. I am just starting to private label some toy products in our niche. Amazon has requested a CPC certification, etc. I purchase from a few suppliers in China. A couple of them say they have CPC docs., Can I use theirs and all their test reports. How can I find out which toy companies in China have CPC certification and third party testing, etc….all the docs needed to do business on Amazon, so that I don’t have to reach out to every company I use to find out. Some of these companies I’ve used haven’t even responded only two have. I just want to make sure everything is legit and correct before I make a large order which is what I was about to do before receiving the notice from Amazon. Any advice would be helpful. Thank you.

      1. Fredrik Gronkvist at 10:36 am

        Hi Michelle,

        If I remember correctly, the CPC must be issued by a US importer or domestic manufacturer.

    3. Phil at 11:08 pm

      hi there
      I was wondering if you can help, advise or any feedback?
      We have done many SGS test and intertek tests and submitted ti Amazon Canada however Amazon continue to rejecting our CPC ?
      they never give any feedback and not sure of you have any experience with this?
      we have followed all available advice how ever there is something missing.
      its been 2 months of back and forth- do you know if there are any special requirements for Canada amazon?

      1. Fredrik Gronkvist at 9:08 am

        Hi Phil,

        Please submit the case information here and we will have a look at it: https://www.compliancegate.com/amazon-case-report/

    4. Nathan Brown at 5:10 pm

      Hi Frederik,

      I have recently submitted CPCs to a US customer of ours for the items we manufacture in China and they are selling on US Amazon. The products have all passed their tests, done by accredited labs, but now the customer is saying that Amazon require the CPC to include the poly bags the FBA sets are packaged in. I know that EU toy standards do not apply to the packaging unless it is an integral part of the toy. Do US standards require the packaging to be included in the CPC, or is this Amazon being overzealous?

      Thanks in advance for your help.

      1. Fredrik Gronkvist at 9:09 am

        Hi Nathan,

        We would need to do additional research before I can say. That said, it would not surprise me if it also covers the bag.

    5. Vlad at 7:42 pm

      Hi Fredrik,
      My company has been selling the inflatable baths for babies on Amazon for two years. Suddenly, Amazon requested a CPC. Our Chinese manufacturer claimed that they don’t have any tests available for us to support the application for the CPC. The product is stored in the US (Nevada). Do you, by chance, have any test lab addresses to share with us?
      Thanks – Vlad

      1. Fredrik Gronkvist at 3:22 pm

        Hi Vlad,

        You can find a list of CPSC accepted labs here: https://www.cpsc.gov/cgi-bin/labsearch/

    6. Farrukh at 7:18 pm

      Hello Fredrik,

      We have CPC,ASTM,CPSIA CPSC certification & testing report but amazon decline it in every attempt & mention the reason that your Consumer registration card does not meet the all the legal requirement set by consumer product safety commission.

      Please help me in this im very thankful to you.

        1. Farrukh at 1:46 pm

          Yes i have followed all the instruction

          1. Fredrik Gronkvist at 3:15 pm

            What did Amazon write to you?

    7. Natasha at 6:57 pm

      Hi I have a CPC Certificate but for some reason Amazon says the details are incorrect. I have no idea which details I need to change. My business is registered in the UK. I have tested and certified the product in china and purchased the product through Alibaba. The product was sent to a warehouse in the US and then sent to the US Amazon warehouse.
      Which company details should I use for the following:
      Country of Origin: is this where my company is located or where the product is from?
      Manufacturer: Is this my UK company details or the China manufacturer?
      Importer: Is this my UK company details?

      1. Fredrik Gronkvist at 12:28 pm

        Hi Natasha,

        Please fill out this form and we’ll have a look at your situation: https://www.compliancegate.com/amazon-case-report/

    8. Rob at 12:06 am

      I am trying to sell children’s clothing on Amazon. My product meets the snug-fit sizing regulations and the pattern is considered a dye-like ink and is part of the substrate therefore possibly exempt from lead testing. Do I still need a CPC for my product? If so, how do I do that if no third-party testing is required? Am I missing anything?

      1. Fredrik Gronkvist at 1:37 pm

        Hi Rob,

        Yes, I still think you need testing, and a CPC is required.

    9. Joe at 4:54 am

      I’ve been going back and forth with Amazon for about a month now regarding our CPC and ASTM reports. Apparently my CPC has a different test lab that the ASTM report that I have. Are you saying that I can just easily edit the CPC to match the ASTM Lab and be good?

      1. Fredrik Gronkvist at 10:06 am

        Hi Joe,

        The CPC is issued by the importer or domestic manufacturer. The CPC is based on the test report.

    10. Jehong Song at 9:41 am

      Hi Fredrik
      Your article was very helpful in preparing CPC.
      I have a question regarding the Importer.
      Our company is located in South Korea and our products are manufactured in China.
      Recently we’ve been assigned an CAIN(Customs Assigned Importer Number) by CBP.
      Can we input this information into the importer information section of the CPC?
      Thank you in advance,
      Jehong

      1. Fredrik Gronkvist at 10:07 am

        Hello Jehong,

        I don’t know if that is accepted. From what I have been told by CPSC, they can accept foreign importers of record, but no idea if CAIN is accepted.

    11. Bernie at 12:26 pm

      “Here is an overview of the information you must include in the CPC:

      3. Importer information (US company name, US address, e-mail, phone)”

      What if I live in Canada and I am an individual seller, having no company?
      Thank you

      1. Fredrik Gronkvist at 1:07 pm

        Then you probably need to setup a US company. I would ask CPSC directly.

    12. Bernie at 10:01 am

      Hello, Thank you so much for this guidance. I went through the CPSC website and got lost: my product is listed under the babies category by Amazon but is intended for use by moms. How can I be sure if my product requires a cpc before creating my listing and ordering my inventory. Thank you so much in advance

      1. Fredrik Gronkvist at 1:08 pm

        Hi Bernie,

        If they list it as a baby product then you can assume that a CPC is needed. I am fairly sure that CPSIA applies to baby carriers etc – not only to products used by children themselves.

    13. ARIANNE at 2:29 am

      I’m sending children’s toys and clothing to USA as a gift only (not for sale). Do I still need to get a CPC? What documents do i need to prepare?

    14. Anthony at 11:49 am

      If you have a certificate of conformity issued from manufacturer can you just change the name to children’s product certificate since both are the same.

      1. Fredrik Gronkvist at 1:54 pm

        No. Most likely that “Certificate of Conformity” is a bogus document. Even if that’s not the case it won’t change the fact that they are not the same thing.

    15. bhavana at 2:51 pm

      Hi Fredrik,
      Is a CPC required if the manufacturer is manufacturing the product in the USA and selling it solely from its own website?

      1. Fredrik Gronkvist at 2:21 pm

        Yes, but then the CPC is issued by the US manufacturer.

    16. Clare Kim at 2:48 pm

      Hi, Fredrik

      This is Clare Kim. I have inquiry for CPSIA test report.

      As I know, CPC should be issued based on CPSIA test report, and CPC should be issued per shipment, then, Could you tell me the validity of CPSIA test report?
      or there is no any validity for CPSIA test report if product is not changed at all?

      Thank you in advance

      Best regards

      Clare

      1. Fredrik Gronkvist at 7:14 pm

        Hi Clare,

        The CPSC says that they require periodic testing. Not sure if they have ever stated that this requires testing on each order.

    17. Martin Dec at 4:01 am

      Thanks for all the information. I am asking if you also also need a label in each product. I read something about this but i am not sure.
      Thanks

    18. Seth at 11:45 pm

      What do I put on the CPC if I am not an American company? I live in X country but I get products made in Bangladesh for sale in the USA. I assume that I still need a CPC but I am not an ‘American Importer’ as such

      1. Seth at 3:17 am

        I realized that a similar question has already been asked and I’ve read your reply. Failing the ability to register a US company, and the shipping company not having a Importer of Record Service (a few do have this option depending on the cargo), can I put the personal details of an American colleague or does it have to be business details?

    19. johnny low at 1:22 am

      Hi Fredrik,

      What can we do if we do not have US address and phone number?

      1. Fredrik Gronkvist at 4:19 pm

        Hi Johnny,

        In that case, you need to get one, either by incorporating in the USA or using the address and phone number of the importer of record (assuming they approve, which I find unlikely)

    20. Jake at 2:48 am

      Hi Fredrik,

      This was a very helpful article. I’m having trouble getting my CPC approved by Amazon as I don’t have a US address. I own a private label product which I’m trying to sell in the US for the first time. Any idea what I should put where it asks for the details of the 1st importer or manufacturer?

      Thanks,
      Jake

      1. Fredrik Gronkvist at 5:34 pm

        Hello Kale,

        Thanks!

        It’s correct that Amazon often requires a US address on the CPC even though this is (as far as I can remember) not required by the CPSC. I don’t think there’s any other way than to register a US company and get a registered address in the USA.

        1. Fredrik Gronkvist at 12:15 am

          Note: I misunderstood this requirement and my understanding is that the CPC should include the address and contact details of either a US manufacturer or a US importer (either a US entity or importer of record)

          1. Szymon at 12:27 am

            Hi Frederik,

            Just to help out. I have contacted the CPSC directly and they informed me that the address on tracking label and CPC doesn’t have to be U.S. Although they have mentioned that some of retailers (Amazon of course :) ) may demand that.

            Best Regards

            1. Fredrik Gronkvist at 10:12 am

              Interesting. I contacted the Small Business Ombudsman a year or so ago and they wrote back that it’s intended to be a “domestic manufacturer or US importer”.

              That said, the lab testing company does not have to be in the US, but that is not the same thing.

    21. Gabby at 7:58 am

      Hi Fredrik
      Your video was very helpful can you suggest any Amazon approved testing companies in the USA? I have a polyester bedroom drapery canopy with glow in the dark stars that will need to be tested. I have contacted SGS today.
      Any help at all would be greatly appreciated
      Thankyou kindly
      Gabby

      1. Fredrik Gronkvist at 11:30 am

        Hi Gabby,

        Amazon doesn’t approve or reject specific labs. They accept test reports from CPSC accepted labs.

        SGS is on that list.

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