Testing according to applicable ASTM standards, which includes ASTM F963, 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 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 of 12 years or younger in the United States. The CPSIA requires all such products to be tested by a third-party testing company approved by the Consumer Product Safety Commission (CPSC).
That said, the CPSIA is not a safety standard in itself but a regulation that requires that you as an importer or domestic US domestic 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 points, loose parts, etc
Further, some testing requirements under the CPSIA are based on CPSC rules rather than ASTM standards.
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.
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 most cases, more than one ASTM standard or restriction applies to a 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 accepted 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 and substance restrictions).
How do I make sure that my product is ASTM F963 compliant in the first place?
You can buy ASTM F963 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 CPSC accepted testing companies:
- TUV Rheinland
- Bureau Veritas
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, 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 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 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 need to 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 then followed up with a “real” CPSIA lab test prior to shipment.
The last thing you want to do is to enter mass production based on a design that is destined to fail CPSIA lab testing due to 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 that 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
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.
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?
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
a. Find a CPSC approved the 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
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 recognizes 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.