• 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.

    Overview

    • What is a Children’s Product Certificate?
    • Why do I need a Children’s Product Certificate?
    • Which products require a CPC?
    • What information do I need to include?
    • Who is responsible for issuing the Children’s Product Certificate?
    • Do I need to create a CPC for each product?
    • Do I need to create a CPC for each new order?
    • Can I get a CPC from my supplier?
    • Do I need to get the CPC approved by a third party?
    • How much does a Children’s Product Certificate cost?
    • Does Amazon require a Children’s Product Certificate?
    • Children’s Product Certificate (CPC) Sample

    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 (name, 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 importer or the manufacturer. In most cases, the CPC is issued by the importer, as contract manufacturers rarely have the expertise to ensure compliance with the CPSIA compliance process.

    Can I get a CPC from my supplier?

    While the CPSC accepts CPCs issued by foreign manufacturers, this is rarely a workable option in practice. The reason being that most contract manufacturers in China and other countries are not compliance experts.

    Further, you cannot use a CPC issued by your supplier for a different product, even if it’s based on the same product model (e.g. SKU).

    Do not seek advice from your supplier when it comes to the CPC. After all, it’s not more difficult than using the CPC template and adjusting certain parts of it.

    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)
    john.li@hk-lab.hk
    +852-1234567890

    You can find CPC templates on the CPSC website.

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