Product Lab Testing Requirements in the United States: An Overview

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Product Lab Testing Requirements United States

Lab testing is necessary when importing and manufacturing most products in the United States. In this guide, we cover US lab testing requirements applicable to children’s products, textiles, furniture, electronics, and many other product categories. We also list US state regulations and standards that may require lab testing.

In addition, you’ll also learn why lab testing is in your interest as an importer or manufacturer when doing so is voluntary.

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Which products require lab testing in the United States?

Lab testing in some form is mandatory for a wide range of products imported and manufactured in the United States. This includes children’s products, electronics, medical devices, and cosmetics. Then there are also products that are not covered by mandatory testing requirements – meaning that lab testing (or at least third-party lab testing) is voluntary.

That being said, lab testing is strongly recommended even if lab testing is voluntary. The reason for this is that importers and manufacturers are still liable in case their products cause injury or property damage.

It’s ultimately in your interest to verify if your products are safe before you start selling – regardless of whether mandatory testing requirements apply.

How do I know which testing requirements apply in the US?

The first step is to research and assess all applicable product regulations, such as Consumer Product Safety Improvement Act (CPSIA) and California Proposition 65. Once this is done, you can determine which standards and substance restrictions apply.

You can also request an assessment from a third-party testing company, as these generally provide a list of applicable standards and regulations as part of a lab test quotation.

CPSIA: Children’s Products

The Consumer Product Safety Improvement Act (CPSIA) covers all children’s products, defined as products for 12-year-olds or younger. Third-party lab testing is mandatory for all products covered by the CPSIA.

Further, lab testing is done according to one or more ASTM standards and CPSC rules. As such, the exact testing requirements differ depending on the product, material, and age group.

The testing procedure generally includes the following:

  • Mechanical and physical properties testing
  • Chemicals and heavy metals testing
  • Flammability testing

The U.S. Consumer Product Safety Commission (CPSC) also requires that all products falling within the scope of the CPSIA are tested by a CPSC accepted testing company.

The testing company and applicable standards must also be specified on the Children’s Product Certificate (CPC), which is mandatory.

Learn more: CPSIA and ASTM F963 Product Lab Testing: A Complete Guide

CPSC Mandatory Standards

The U.S. Consumer Product Safety Commission (CPSC) provides a list of products that are covered by one or more regulations, standards, and or bans. The specific requirements differ depending on the product – but include substance restrictions, labeling, flammability, and general product safety requirements.

Here are some examples of listed products:

  • Art Materials
  • Baby bouncers/jumpers/walkers
  • Bicycles
  • Bunk Beds
  • Candles with metal-cored wicks (lead)
  • Cigarette lighters

Third-party lab testing under these rules is not always mandatory – but is nonetheless necessary for the sake of verifying that your product is compliant with all mandatory standards and bans.

Learn more: General Certificate of Conformity (GCC): A Practical Guide

Apparel & textiles

Apparel and textiles are covered by various standards and regulations in the United States. Here are some examples:

  • CPSIA: Children’s clothing
  • Flammable Fabrics Act (FFA)
  • California Proposition 65

Whether lab testing is required depends on the age group, fabric weight, and the states in which you intend to sell the textiles products.

Here are some aspects that may be included in the textiles lab testing procedure:

  • Small parts
  • Flammability
  • Chemicals and heavy metals

Learn more: Clothing & Textiles Product Lab Testing in the United States

Electronics

UL Standards

Underwriter Laboratories (UL) develop standards applicable to a wide range of products, including electronics. Here are some examples:


Examples

UL 1642, Lithium Batteries

UL 60950-1, Information Technology Equipment – Safety, Part 1: General Requirements

UL 60950-21, Information Technology Equipment – Safety, Part 21: Remote Power Feeding

UL 1026, Electric Household Cooking and Food Serving Appliances


Compliance and testing according to UL standards is often voluntary when importing and manufacturing electronics in the United States. However, importers and manufacturers are still liable in case of injury or fire caused by their devices.

As such, ensuring compliance with the relevant UL standards, which includes lab testing, is therefore in the interest of US importers and manufacturers – regardless of whether lab testing is mandatory or not.

Learn more: UL Standards Lab Testing: A Complete Guide

FCC Rules

Electronics imported or manufactured in the United States must comply with various FCC regulations and standards.


Examples

ANSI C63.4 – Measurement of Radio-Noise Emissions from Low-voltage equipment in the range of 9kHz to 40 GHz

ANSI/SCTE 54 – Digital video services multiplex and transport system standard for cable television

ANSI/SCTE 65 – Service Information Delivered Out-of-Band for Digital Cable Television

ANSI C63.10 – Compliance testing of unlicensed wireless devices


The specific testing requirements differ depending on the product type. Further, devices are often classified as intentional or unintentional radiators. This classification also impacts the testing and compliance procedure.

Learn more: ​​FCC Product Lab Testing: A Complete Guide

Furniture

Furniture imported and manufactured in the United States is covered by substance restrictions, flammability standards, and general safety standards. Here are some examples of standards that may be included in a furniture testing protocol:


Examples

16 CFR Part 1640 – Standard for the Flammability of Upholstered Furniture

California Technical Bulletin 117-2013

ASTM F2057-19 – Standard Safety Specification for Clothing Storage Units

California Proposition 65


Learn more: California Technical Bulletin 117-2013 (TB 117-2013): An Overview

Food Contact Materials

21 CFR restricts substances in food contact materials, which includes kitchen utensils, food processing appliances, food packaging materials, drinkware, and other materials in contact with food and beverage.

Lab testing is necessary for the sake of ensuring that the food contact material does not contain excessive amounts of restricted chemicals, heavy metals, and other substances.


Examples

General Indirect Food Additives (21 CFR 174)

Adhesives and Components of Coatings (21 CFR 175)

Paper and Paperboard Components (21 CFR 176)

Polymers (21 CFR 177)

Adjuvants, Production Aids, and Sanitizers (21 CFR 178)

Irradiation in the Production, Processing, and Handling of Food (21 CFR 179)


Learn more: Food Contact Materials Regulations in the United States: An Overview

Toxic Substances Control Act (TSCA)

The Toxic Substances Control Act (TSCA) regulates both chemicals and substances found in certain consumer products. The TSCA restrics formaldehyde emissions in composite wood products.

  • Hardwood plywood < 0.05 ppm
  • Particleboard < 0.09 ppm
  • Medium-density fiberboard < 0.11 ppm
  • Thin medium-density fiberboard < 0.13 ppm

TSCA requires that composite wood products must be tested in accordance with ASTM testing standards, which are:

a. ASTM E1333-14 Standard Test Method for Determining Formaldehyde Concentrations in Air and Emission Rates from Wood Products Using a Large Chamber

b. ASTM D6007-14 Standard Test Method For Determining Formaldehyde Concentrations In Air From Wood Products Using A Small-Scale Chamber

Further, the TSCA restricts the following PBT (persistent, bioaccumulative, and toxic chemicals) in consumer products:

  • 2,4,6-TTBP< 0.3% by weight
  • DecaBDE: Prohibited
  • PIP 3:1: Prohibited)
  • PCT < 1% by weight
  • HCBD: Prohibited

Here we list some examples of products that might contain restricted PBT:

  • Power sockets
  • Plastic components for electronic products
  • Cables
  • Textile products
  • Upholstered furniture

Lab testing might be required to verify that your products don’t contain an excessive amount of restricted PBT.

Learn more: Toxic Substances Control Act (TSCA) Guide for US Importers

California Proposition 65

California Proposition 65 restricts chemicals and heavy metals in products sold in California. Such substances include lead, cadmium, and phthalates – many of which are commonly found in plastics, alloys, printing inks, and other materials.

The purpose of California Proposition 65 is to reduce substances that can cause cancer, reproductive problems, or birth defects.

Products that may contain excessive amounts (above the set limits) of such substances must carry a warning label. Lab testing is required in order to determine if a product does contain such substances above the limits.

Learn more: California Proposition 65 Product Lab Testing: A Complete Guide

Other US State Regulations

Importers and manufacturers in the United States must also take state-level product regulations, standards, and bans into consideration. Lab testing is often necessary, either because it’s mandatory or because it’s the only way to verify if a product is compliant


Examples

Washington: RCW 70.280: Bisphenol A Restrictions

Oregon: Toxic-Free Kids Act

New York: A01554: Toys and child care products containing phthalates

Texas: Hazardous Substances Act (HSA)

Pennsylvania: Stuffed Toy Manufacturing Act

Massachusetts: Act to Protect Children, Families, and Firefighters From Harmful Flame Retardants

Michigan: Lead Poisoning Prevention Program

Maryland: Child Care Articles Containing Bisphenol-A Prohibited


Learn more

Product Safety Standards & Regulations in California: An Overview

Product Safety Standards & Regulations in Washington: An Overview

Product Safety Standards & Regulations in Illinois: An Overview

Product Safety Standards & Regulations in New York: An Overview

Product Safety Standards & Regulations in Florida: An Overview

Product Safety Standards & Regulations in Oregon: An Overview

Product Safety Standards & Regulations in Texas: An Overview

Product Safety Standards & Regulations in Pennsylvania: An Overview

Product Safety Standards & Regulations in Virginia: An Overview

Product Safety Standards & Regulations in Iowa: An Overview

Product Safety Standards & Regulations in North Carolina: An Overview

Product Safety Standards & Regulations in Vermont: An Overview

Product Safety Standards Regulations in Nevada: An Overview

Product Safety Standards & Regulations in Michigan: An Overview

Product Safety Standards & Regulations in Maine: An Overview

Product Safety Standards & Regulations in Arizona: An Overview

Product Safety Standards & Regulations in New Hampshire: An Overview

Product Safety Standards & Regulations in Ohio: An Overview

Product Safety Standards & Regulations in Massachusetts: An Overview

Product Safety Standards & Regulations in Georgia: An Overview

Product Safety Standards & Regulations in New Jersey: An Overview

Product Safety Standards & Regulations in Wisconsin: An Overview

Product Safety Standards & Regulations in Tennessee: An Overview

Product Safety Standards & Regulations in Connecticut: An Overview

Product Safety Standards & Regulations in Colorado: An Overview

Product Safety Standards & Regulations in Maryland: An Overview

Product Safety Standards & Regulations in Missouri: An Overview

Product Safety Standards & Regulations in South Carolina: An Overview

Product Safety Standards & Regulations in Indiana: An Overview

Product Safety Standards & Regulations in Alabama: An Overview

Product Safety Standards & Regulations in Minnesota: An Overview

Product Safety Standards & Regulations in Kentucky: An Overview

Product Safety Standards & Regulations in Louisiana: An Overview

Product Safety Standards & Regulations in Utah: An Overview

Product Safety Standards & Regulations in Arkansas: An Overview

Product Safety Standards & Regulations in Puerto Rico: An Overview

Product Safety Standards & Regulations in Oklahoma: An Overview

Product Safety Standards & Regulations in Mississippi: An Overview

Product Safety Standards & Regulations in Nebraska: An Overview

Product Safety Standards & Regulations in Kansas: An Overview

Product Safety Standards & Regulations in Idaho: An Overview

Product Safety Standards & Regulations in West Virginia: An Overview

Product Safety Standards & Regulations in New Mexico: An Overview

  • (USA & EU)

    We Help Brands & Importers With Product Compliance (US & EU)

    • Product Requirements Lists
    • Product Certification
    • Product & Packaging Labeling
    • Lab Testing

    BOOK A FREE CONSULTATION


    Disclaimer: The content on this website is provided for general information only. The content includes summaries written by our team members based on publicly available information about product safety standards, labeling, documentation, testing, processes, and other product compliance related topics. However, we don’t guarantee that we cover every single relevant regulation/standard/requirement, or that the information is free from errors, or covering every single scenario and exemption. We do make mistakes from time to time. We never provide legal advice of any sort.

    Changes/Updates: Product standards and substance restrictions are subject to frequent updates and changes. In addition, new regulations, standards, and/or requirements may also become effective at any time. We don’t update our articles whenever new standards/regulations/rules are added or changed. We recommend that you consult a lab testing company or other professional to get the latest information about mandatory standards/regulations in your market, country, or state. Lab testing companies generally stay up to date on new and updated standards and regulations.

    National/State-Level Standards/Regulations: Many articles don't cover all European national and US state standards, regulations, and requirements. We recommend that you consult a testing company or other professional to confirm all relevant (and current) national/state level standards and regulations.
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