Importing footwear to the United States or selling on Amazon.com? In this article, we cover the basics of footwear compliance in the US, including safety shoe requirements, children’s footwear, chemicals, and heavy metals regulations, packaging regulations, labeling and much more.
- Work footwear
- Safety shoes
- Leather shoes
- Children’s footwear
- Sports shoes
- Special purpose shoes
Safety Shoes and Work Footwear: OSH Act
If you are importing workers’ shoes to the US, then your products should adhere to the requirements of the Occupational Safety and Health Act (OSH Act), which intends to protect the safety of working men and women at the worksite.
Employers must provide PPE (Personal Protective Equipment) to the workers at worksites that might pose physical threats to the employees. PPE includes workers’ shoes, worker’s gloves, protective garments, and more.
Standards for working footwear
According to the requirements formulated by the Occupational Safety and Health Administration (OSHA), the employer shall ensure its employees use protective footwear when working in areas where might have potential hazards and could lead to foot injuries caused by “falling or rolling objects, or objects piercing the sole”, or dangers such as “static-discharge or electric-shock”.
The OSHA mandates that protective footwear must comply with one or more of the following consensus standards:
a. ASTM F-2412-2005, “Standard Test Methods for Foot Protection”
b. ASTM F-2413-2005, “Standard Specification for Performance Requirements for Protective Footwear”
c. ANSI Z41-1999, “American National Standard for Personal Protection – Protective Footwear”
d. ANSI Z41-1991, “American National Standard for Personal Protection – Protective Footwear”
29 CFR 1910 outlines the test requirements for products covered by the OSHA.
You can contact Bureau Veritas, TUV or another established lab that offers testing against ASTM or ANSI standards in order to know more about this topic.
Generally speaking, only the Country of Origin label, which we discuss more in detail below in this section, is required for imported footwear in the US.
However, most manufacturers and importers also add information about material content and size. Additionally, footwear products that contain wool, leather, or fur have additional requirements that can be found here.
If the footwear products you import include leather, they fall under the supervision of the FTC’s (Federal Trade Commission) 16 CFR (Code of Federal Regulations) Part 24, which regulates the labeling of leather products. According to the regulation, it is considered misleading to inaccurately specify the leather type, including but not limited to the following:
- Material content
For example, if the leather shoes are made of non-genuine leather materials, you should specify on the product labels or instructions that the shoes were not made of leather. Instead, you should use words such as not leather, imitation leather, simulated leather, vinyl, vinyl-coated fabric, or plastic.
In addition, importers should carefully use the following descriptive words for the leather shoes, in order to avoid misleading the buyer:
- Warp proof
- Scuff proof
- Scratch proof
- Scuff resistant
For more detailed information, check FTC’s guidelines on leather labeling.
Country of Origin
Federal law requires that all products sold in the US market must have labels indicating their country of origin. The mark for the country of origin must be permanently printed, stamped, or otherwise affixed to the product or its packaging, instead of merely displayed on a sticker.
- Made in China
- Made in Vietnam
- Made in Malaysia
- Made in India
- Made in Mexico
Creating a file specifically for the document of the country of origin and share it with your manufacturer is a necessary procedure before mass production. We recommend that you use .ai or .eps formats when creating the file.
Children’s Footwear: CPSIA
The Consumer Product Safety Improvement Act (CPSIA) is applicable to all children’s products, including footwear for children of 12 years or younger. Ensuring CPSIA compliances involves mandatory lab testing, the creation of a tracking label, children’s product certificate (CPC), testing plan and more.
You can learn about CPSIA more in these guides:
- CPSIA and ASTM F963 Product Lab Testing: A Complete Guide (Link)
- CPSIA Children’s Product Certificate (CPC): A Practical Guide (Link)
- CPSIA Tracking Label Guide For Importers & Amazon Sellers (Link)
California Proposition 65
California’s Proposition 65 was enacted with the purpose of regulating the concentration of hazardous substances in the products manufactured, imported and sold in California and allow its citizens to make informed decisions about protecting themselves from chemicals that could cause cancer, birth defects, or other reproductive harm.
California Proposition 65 currently includes more than 800 kinds of toxic or dangerous chemicals, and the list still expanding every year.
When importing footwear products to the US, importers should concern about the compliance issue of their products to California Proposition 65.
Examples of restricted substances
California Proposition 65 Lab testing
In order to verify the compliance of the footwear products, importers should contact a third-party lab-testing company for product compliance tests before mass import.
Kindly note that most of the footwear manufacturers in China and Southeast Asia are not able to provide the California Proposition 65 Lab test reports.
CA prop 65 testing costs are calculated based on the following factors:
- Number of materials (e.g. inner sole, outer sole, upper leather, and textile parts)
- Number of components (e.g. buttons and zippers)
Shoes and other footwear often consist of numerous materials and components, which therefore drive up the testing cost. For example, sneakers could cost more than $1200 per SKU which requires testing.
Click here to find out about specific companies that provide California Proposition 65 lab testing services.
In some cases, instead of subjecting your product to California Proposition 65 third-party testing, it is permissible to attach a warning label to the product or its packaging. When applicable, this is the only acceptable alternative to third-party testing.
Certain materials and parts used in footwear manufacturing contain excessive amounts of heavy metals and chemicals restricted by California Proposition 65. Here are a few examples:
- Zippers, buttons and other parts containing excessive amounts of lead
- PU leather and PVC containing excessive amounts of phthalates
- Dyes and coating containing excessive amounts of lead
Packaging materials, just like the main products, should also be compliant with the relevant standards. Here is an example of the main package regulations.
Heavy Metals Restrictions
In the US, individual states have different statutes that set the levels of heavy metals such as lead, cadmium, and mercury allowed in packaging materials, dyes, and printing inks.
To determine whether your packaging materials are compliant with these standards, importers must contact a third-party laboratory testing company such as Bureau Veritas, TUV, or QIMA and have a comprehensive lab-test on the materials.
Importers may be required that the packaging display relevant applicable compliance marks and/or country of origin along with other labels.