CPSIA lab testing is mandatory when importing and selling toys and other children’s products in the United States. This guide answers the essential questions about CPSIA and ASTM testing that all importers and Amazon sellers must know.
What is CPSIA lab testing?
The Consumer Product Safety Improvement Act (CPSIA) applies to all children’s products for children of 12 years or younger in the united states. The CPSIA requires all such products are tested by a third-party testing company approved by the Consumer Product Safety Commission (CPSC).
That said, the CPSIA is not a safety standard, but requires that you as an importer or domestic US manufacturer ensure that your product is compliant with all applicable ASTM standards, such as ASTM F963 – 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 edges, loose parts, etc
The purpose of the lab test is to verify that your product is technically compliant with CPSIA, and you’ll receive a test report used to prove this.
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 laboratory tested by a CPSC approved third-party testing company.
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.
Can I use a test report from my supplier?
No, you cannot 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, existing test reports for previous orders cannot be applied to your production – even if it’s the same product, material, and supplier.
2. 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.
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 products with different dimensions, materials or colors.
This is also the case if you change the manufacturer.
Do I need to test my products each time we place an order?
While you don’t necessarily have to test every single order, at a minimum, 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)
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 approved by the CPSC for the test report to be valid. If not, you’re just wasting your money.
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 are matching 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?
Yes. It doesn’t matter if ‘similar products’, even if they originate from the same manufacturer. It’s by definition not “the same product” unless it’s the exact same production run.
Even if the product originates from the same factory, it doesn’t prove that the product is made using the same materials or internal components.
How to confirm applicable ASTM and other standards
In most cases, more than one ASTM standard (or parts) applies to a certain product. Here is one example:
- ASTM F963-17-Toys-Mechanical Hazards
- ASTM F963-17-Toys-Flammability of Solids
- ASTM F963-17-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 approved lab testing company such as QIMA or Intertek for a quotation, in which case they always present their assessment (e.g. a list of ASTM standards).
How to manage your lab test booking
a. Find a CPSC approved the testing company
Only a test report issued by a CPSC approved testing company is valid. As such, you must identify one from the CPSC approved 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
b. How to submit product samples
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 that 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.
c. Confirm quotation
The testing company will send a final quotation once they’ve received the product samples. It can look something like this:
|ASTM F963-17-Toys-Mechanical Hazards||100|
|ASTM F963-17-Toys-Flammability of Solids||80|
|ASTM F963-17-Toys-Soluble Heavy Metals Content||80|
|CPSIA Section 101-Children’s Products-Total Lead (Pb) Content||100|
|Total cost (US Dollars)||360|
d. Receive test report
Once the test is done, which normally takes around a week, you’ll 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 F963-17-Toys-Mechanical Hazards||1||50|
|ASTM F963-17-Toys-Flammability of Solids||1||50|
|ASTM F963-17-Toys-Soluble Heavy Metals Content||1||50|
|CPSIA Section 101-Children’s Products-Total Lead (Pb) Content||1||100|
|Total cost (US Dollars)||200|
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 F963-17-Toys-Mechanical Hazards||4||50|
|ASTM F963-17-Toys-Flammability of Solids||4||50|
|ASTM F963-17-Toys-Soluble Heavy Metals Content||4||50|
|CPSIA Section 101-Children’s Products-Total Lead (Pb) Content||4||100|
|Total cost (US Dollars)||800|
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.
List of CPSIA lab testing companies
The CPSC only recognize test reports issued by approved lab testing companies. Here are a few examples:
- Bureau Veritas
You can find the full list on the CPSC website.