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.
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.
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
- 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.
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
- Chemicals and heavy metals
Underwriter Laboratories (UL) develop standards applicable to a wide range of products, including electronics. Here are some 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
Electronics imported or manufactured in the United States must comply with various FCC regulations and standards.
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 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:
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
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.
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)
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
- Textile products
- Upholstered furniture
Lab testing might be required to verify that your products don’t contain an excessive amount of restricted PBT.
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.
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
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