Issuing a Children’s Product Certificate (CPC) is mandatory when importing or manufacturing toys and other children’s products in the United States. Doing so requires that you know how to correctly input information about the product, your company, and the CPSC accepted lab testing company that has tested your products.
In this guide, you will learn what to include in your CPC, while avoiding some of the more common mistakes we’ve encountered.
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What is a Children’s Product Certificate?
A Children’s Product Certificate (CPC) is a document issued by the importer or (domestic) US 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 marketplaces 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. Without a lab test report issued by a CPSC accepted lab testing company you cannot create a complete CPC:
Which products require a Children’s Product Certificate?
The CPC is mandatory for all products covered by the Consumer Product Safety Improvement Act (CPSIA). Generally 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 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
- Children’s clothing
- Baby products
- Children’s furniture
- Children’s Accessories
- Children’s Jewellery
- Toy vehicles
- Wooden toys
Do I need to create a Children’s Product Certificate 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 Children’s Product Certificate 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
Comment: This is normally a product description and model number/SKU
2. List of applied and mandatory ASTM and CPSC standards (e.g ASTM F963)
Comment: You can request a list of applicable ASTM and CPSC standards from a CPSC accepted lab
3. Importer or domestic manufacturer information (US company name, US address, e-mail, phone)
Comment: Specify your company details
4. Contact information of the person with access to the test report (name, address, e-mail, phone)
Comment: This is normally a person in your company
5. Manufacturing location (city, province, country) and date (month, year)
Comment: This can be a location in the US or overseas (e.g. China or Vietnam)
6. Testing date (month, year) and location (city, province, country)
Comment: This can be a location in the US or overseas (e.g. China or Vietnam)
7. CPSC accepted third-party lab testing companies (company, contact person, address, phone, e-mail)
Comment: This can be a lab located in the US or overseas (e.g. China or Vietnam) – as long as its CPSC accepted
How do I know which ASTM and CPSC standards to list in the CPC?
The referenced ASTM standards and CPSC standards must reflect those in the lab test report. In short, you specify the standards that apply to your product and which your product has been tested according to.
You can either research applicable standards yourself, or get help from a lab testing company. Most testing companies will assess the applicable ASTM and CPSC standards when they offer a quote.
Do I need a lab test report before I can issue a CPC?
Yes, you need to include the following information which requires that you already have a lab test report:
4. Contact information for the individual maintaining records of test results:
Steven Stevenson, Procurement Manager
Wooden Toys LLC
123 Street, Los Angeles, CA 56789
6. Date and place where this product was tested for compliance with the regulation(s) cited above:
Example: August 2023, Kowloon, Hong Kong S.A.R (China)
7. 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)
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 Children’s Product Certificate must 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 Children’s Product Certificate from my supplier in China (or elsewhere)?
It is extremely rare that manufacturers in China, or elsewhere outside the United States for that matter, know what a CPC is and much less how to create one. Further, if you import the product into the US then the CPC should include details about your company.
Further, even in the unlikely scenario in which your supplier does have a CPC, it cannot be applied to a new production run without a new lab test report. In other words, you cannot use a CPC issued, for example, 2 years ago and apply it to your product batch – even if it’s the exact same product design.
Do I need to get the Children’s Product Certificate 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?
It doesn’t cost anything to create a Children’s Product Certificate. The CPC is a self-issued document, not a permit or a license you buy or obtain from the government or any third party.
That said, the CPC is based on the lab 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 a standard or regulation listed on the test report is missing – and vice versa.
Do I need a Children’s Product Certificate if other US companies are already selling the same product?
Yes, the fact that other companies in the US are selling ‘the same’ or ‘similar’ products does not mean that you are exempt from issuing a CPC. A Children’s Product Certificate only applies to a specific importer or domestic manufacturer and the listed products.
Further, it must also be supported by a lab test report – which in turn must be done on the same batch of products you import and sell in the United States.
Keep in mind that products that look identical to yours may not be made using the same materials and components.
Do I need a Children’s Product Certificate when selling private label products?
Yes, issuing a CPC is mandatory regardless of whether its a product you’ve designed or if its a private label product designed by the manufacturer.
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
Contact information for the individual maintaining records of test results:
Wooden Toys LA LLC
9015 Sunset Blvd
Los Angeles, California
Date and place where this product was manufactured:
June 2023, District 9, Ho Chi Minh City, Vietnam
Date and place where this product was tested for compliance with the regulation(s) cited above:
August 2023, 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)
You can find CPC templates on the CPSC website.
70 Responses to “CPSIA Children’s Product Certificate (CPC): A Practical Guide”
Hy! how can I know which lab is approved for cpc in china where I should apply for cpc and test report?
I am trying to create a COC for children’s clothing. I am still confused on where to place things on the template. For example, I am using a fabric in my hoodies that is exempt from testing. What articles do I place in step 2 on the template and what do I put where it asks for third party testing since it’s exempt from testing l?
Hi – My company created a game, manufactured in China, that is intended for adults with cognitive disorders, primarily Alzheimer’s disease and other dementias. The game consists of a number of heavy cardboard tiles, apx. 2″ square, with a photo image printed on each tile, and the packaging. We sell this primarily on our website, https://best-alzheimers-products.com/, but we do wholesale it to a few other companies for resale. Some of these do sell it as a children’s game, and it works well for that in certain cases. Since it is intended as a game for adults with dementia do we need a COC? If so, where do I find a request form?
You can find the CPSCs definition of a children’s product here:
It could perhaps be relevant if children participate in the game.
Your article is very helpful!
1) When I have variants of the product, how many tests do I need? I’d like to sell them on Shopify. (For example, pink in size01, pink in size 02, green in size 01, green in size 02)
2) Do they need to be tested every time I order?
Thanks in advance!
1. Each variation must be tested, but it might be possible to avoid re-testing the same materials more than once. The same thing goes for certain mechanical safety aspects.
2. The CPSC requires a “periodic” testing plan and I think I recall that they recommend batch testing for importers.
Your information is very helpful. I have registered my limited in Hong Kong and planning to sell some China-manufactrured children products on US amazon. Much appreciated if you can help clarify:
1) Identity of US importer: My hong kong-registered limited company is sufficent?
2) US contact and address: is it necessary as i just browsed CPSC website and seems it is not required. Thanks
I am starting a new company creating fun at-home craft kits for kids. In the beginning, do I need to get my CPC license before anything is even sent out? I’m not even sure people will purchase the product so it feels unnecessary to get a CPC before I have validated that there is demand for the product. Could I wait until I have sold a few products to invest in a CPC?
No. You must have a CPC, and test report, before you sell anything.
Hello Fredrik. Question – I am about to make a big purchase for children’s products from China, to ship to Amazon warehouse, however before I do could I ask the manufacturer if they have recent test results for the product and if they do could this recent test result be used? If not would I be then required to get a sample from the manufacturer and ship it to a approved Testing lab in China ?
Also do I need to include in each product a sample of this certificate ? Basically do I need to ask my manufacturer before shipping to put a sample of the certificate in each and every product ?
1. No I don’t think you can use old test reports to prove compliance. Batch testing is usually needed.
2. No, the product is not shipped with the CPC to consumers, but it must carry a tracking label.
Also, you will end up with a major loss if you expect your supplier to get this done properly (on their own). That is not going to happen.
What is a tracking label?
It’s explained here: https://www.compliancegate.com/cpsia-tracking-label/
I have a question regarding creating new CPS. In the template I can see the following “Date and place where this product was manufactured”. So let’s say I import items from the same manufacturer in April and in September. For the shipment in April I stated that the items were manufactured in March. Items in the second shipment will definitely be manufactured later. So it would seem I need to create a new CPC for each shipment…Am I thinking correctly?
Yes, you would need a new CPC for each shipment. The same applies to the tracking label.
Can I as the importer issue a CPC based on test report issued by a CPSC accepted lab but engaged by the Chinese manufacturer (in other words, the test reports were addressed to the manufacturer but on the same product within a reasonable period of time, say 3-6 months before import into USA)? Put it the other way around, do I have to have a test report from a lab addressing to my company as the importer so that I can issue the CPC on that basis?
Hi, I’ve been reading many articles and I’m still at a lost. I’m trying to manufacture a board game and flash cards for children. I was told by my manufacture that a CPC is not required but my shipping company disagrees. I called the CPSIA hotline and was told testing is likely not required since it’s printing on cardboard and paper, however a CPC is required. Do I create the CPC myself since testing is not required? If I purchase your access to your website, will that help me with creating a CPC? Also, what’s your experience, do you think CPC is required? I look forward to your response.
clarification, the board game is a memory matching game that is printed on a 2.5×2.5 cardboard .
1. Never take advice from your suppliers when it comes to product compliance
2. Strange. I have never heard of testing exemptions like that. I still think chemicals and heavy metals testing (covered by ASTM F963) can be applied.
3. Yes you still issue your own CPC
4. If it’s a children’s product then a CPC is required
5. Yes, you can use our platform to create a CPC. Learn more here: https://www.compliancegate.com/cpsia/
A question about the production date on the labels. I have been in the production process with a factory since 2021, selecting. The actual sewing will begin this month. Does the production date reflect the date that the process began or the date that the production is completed? I created and sent the labels to the manufacturer in 2021 so that’s the date that’s showing. Do I need to update it to 2022 since that’s when they will be completed?
I think they primarily want you to be able to trace it to a certain product run/batch. If I remember correctly, they don’t state on the CPSC website whether it must be the month production starts or finishes.
That said, if you placed your order in 2022 and production starts this year then this should be reflected.
Hi, we have submitted our CPC and Test Report to amazon. We are selling in the Toys category. Our product is the pop it bag for girls. Amazon has asked us for the following information: manufacturer name, address and warning label on the product/packaging. Is this typical of them to ask? and how do I include this now in our test results. The report was made by our chinese supplier in China. Looking forward to your reply. thanks!
Yes, you need to assign a tracking label. You can learn more here: https://www.compliancegate.com/product-labeling/
Good Day Fredrik, interesting article indeed thank you.. However, I got a little confused Mid-Way. For example: if a children’s toy is being produced in China for the purpose of exporting it to the U.S.A/Amazon store, Who is responsible for Testing the product, and Issuing the CPC? Is it the Exporter that intends to ship the products to their client in the USA, Or My client has to receive samples first and carry out the Testing at a CPSIA accredited lab? In order for them to draft a CPC based on the Test Report? Or is it possible to receive the latest test report from the Chinese Manufacturer and Draft a CPC Myself (as the exporter) and ship the test report copy and CPC with the shipment. Thank you
The manufacturer cannot issue a test report. It must be issued by a CPSC accepted lab.
Is your client importing the product into the US? Then the most common practice is that they issue the CPC based on a test report valid for the exact same product (color, materials, design) that they import.
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
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.
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.
If I remember correctly, the CPC must be issued by a US importer or domestic manufacturer.
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?
Please submit the case information here and we will have a look at it: https://www.compliancegate.com/amazon-case-report/
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.
We would need to do additional research before I can say. That said, it would not surprise me if it also covers the bag.
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
You can find a list of CPSC accepted labs here: https://www.cpsc.gov/cgi-bin/labsearch/
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.
Does the card include all the information specified on this page?
Yes i have followed all the instruction
What did Amazon write to you?
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?
Please fill out this form and we’ll have a look at your situation: https://www.compliancegate.com/amazon-case-report/
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?
Yes, I still think you need testing, and a CPC is required.
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?
The CPC is issued by the importer or domestic manufacturer. The CPC is based on the test report.
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,
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.
“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?
Then you probably need to setup a US company. I would ask CPSC directly.
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
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.
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?
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.
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.
Is a CPC required if the manufacturer is manufacturing the product in the USA and selling it solely from its own website?
Yes, but then the CPC is issued by the US manufacturer.
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
The CPSC says that they require periodic testing. Not sure if they have ever stated that this requires testing on each order.
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.
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
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?
What can we do if we do not have US address and phone number?
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)
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?
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.
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)
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.
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.
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
Amazon doesn’t approve or reject specific labs. They accept test reports from CPSC accepted labs.
SGS is on that list.