Consumer Product Regulations in the United States: An Essential Guide

Safety standards, chemical restrictions, labeling, certification, and testing requirements apply to most consumer products imported and manufactured in the United States. In this guide, we provide a comprehensive overview of product regulations applicable to country of origin labeling, textiles, children’s products, electronics, medical devices, wooden products, and much more.

Note: This guide does not cover all product regulations and compliance requirements in the United States. Further, this guide only covers a limited number of state-level product regulations and rules.

19 CFR 134 – Country of Origin Marking

Country of origin labeling is required for most consumer products imported or manufactured in the United States. The country of origin labeling can be applied both to the product and the packaging.

Further, the country of origin label must accurately represent the actual manufacturing country. For example, you cannot claim that a product assembled in China but repacked in the US is ‘Made in the USA’.

Examples

• Made in USA
• Made in China
• Made in Germany
• Made in Mexico

Learn more

• Country of Origin Requirements in the United States (Link)

Textile Fiber Products Identification Act

Apparel and some other textile products must carry a textile fiber label. This includes the following information:

• Fiber content (e.g. 100% cotton)
• Manufacturer/importer identity
• Care instructions

The label must be permanent, meaning that a sticker or other removable label is not sufficient. Further, the manufacturer or importer identity can be replaced with an RN number.

Product Examples

• Clothing
• Curtains and casements
• Rugs, carpets, and mats
• Cushions

Exemptions

Here are some exempt textile products:

• Bags
• Belts
• Diaper liners

Learn more

• Clothing and Textiles Regulations in the United States (Link)
• Registered Identification Number (RN) Guide for United States Importers (Link)

Consumer Product Safety Improvement Act (CPSIA)

The Consumer Product Safety Improvement Act (CPSIA) covers all children’s products imported and manufactured in the United States. Children’s products are defined as all products intended (or commonly recognized as suitable) for children aged 12 years or younger.

As such, the CPSIA is not only applicable to toys, but children’s clothing and furniture, baby carriers, and other children’s products.

Children’s products must be compliant with applicable ASTM and CPSIA standards, such as ASTM F-963. Hence, the first step of the process is to assess which standards apply to a certain product. Different standards apply to, for example, teddy bears as compared to children’s bunk beds.

Third-party lab testing is mandatory for all products covered by the CPSIA. Further, only test reports issued by CPSC accepted labs are valid. This is done in order to verify compliance with all applicable ASTM and CPSIA standards.

CPSIA also covers small parts restrictions, labeling requirements, and children’s product certification. Products classified as ‘durable baby and infant products’ must also include a postage-paid product registration card.

Product Examples

• Children’s Toys
• Children’s Clothing & Babywear
• Children’s Footwear
• Children’s Jewelry
• School and Stationery Items
• Children’s Furniture
• Baby Cribs and Bassinets
• Baby Strollers and Carriers

Learn more

• List of Products Covered by CPSIA: An Overview (Link)
• CPSIA and ASTM F963 Product Lab Testing: A Complete Guide (Link)
• CPSIA Tracking Label Guide For Importers & Amazon Sellers (Link)
• CPSIA Children’s Product Certificate (CPC): A Practical Guide (Link)
• CPSIA Durable Infant or Toddler Products Guide (Link)
• CPSIA Requirements For Amazon Sellers: Frequently Answered Questions (Link)

Flammable Fabrics Act (FFA)

The Flammable Fabrics Act (FFA) requires that certain fabrics comply with flammability standards. Here are some examples:

• 16 CFR Part 1610 – Standard for the Flammability of Clothing Textiles

• 16 CFR Part 1611 – Standard for the Flammability of Vinyl Plastic Film

• 16 CFR Part 1615 – Standard for the Flammability of Children’s Sleepwear: Sizes 0 Through 6X

• 16 CFR Part 1616 – Standard for the Flammability of Children’s Sleepwear: Sizes 7 Through 14

Product Examples

• Apparel
• Children’s sleepwear
• Mattresses
• Carpets
• Upholstered Furniture

Learn more

• Flammable Fabrics Act (FFA) Guide For United States Importers (Link)
• Furniture Flammability Safety Standards in the United States: An Overview (Link)

Poison Prevention Packaging Act (PPPA)

The Poison Prevention Packaging Act (PPPA) sets requirements concerning the safety of household product packaging. PPPA aims to ensure that children are not exposed to potentially harmful substances that can be found in certain household items, such as cleansers and mouthwash containing ethanol.

Verifying compliance requires that the packaging undergoes a testing procedure in order to make sure that the packaging is child-resistant.

Product Examples

• Cosmetics
• Mouthwash products
• Baby oils
• Painting kits
• Storage batteries
• Polishing products

Learn more

• Poison Prevention Packaging Act (PPPA) for United States Importers (Link)

Federal Hazardous Substances Act (FHSA)

The Federal Hazardous Substances Act (FHSA) sets warning, precaution, and storage labeling requirements for certain household products, such as cleansers and flammable liquids. The label information must also provide information about steps that must be taken in case of an accident.

Product Examples

• Cleansers
• Acid
• Flammable liquids
• Pool chemicals
• Fireworks

Learn more

• Federal Hazardous Substances Act (FHSA) Requirements (Link)

47 CFR Part 15 (FCC)

Title 47 CFR Part 15 is an FCC rule applicable to electronics sold in the United States. It classifies electronic devices as intentional or unintentional radiators. Further, there are also different device classes within these categories – all of which impact the compliance requirements, process, and required documentation.

Third-party lab testing is often necessary for the sake of verifying that the device is compliant with the applicable FCC rules. Further, lab test reports are often used as supporting documentation for the Supplier’s Declaration of Conformity (SDoC) or other certificates.

FCC labeling, including a device ID, is also a requirement for many device types.

Intentional Radiators Examples

Intentional radiators cover radio-enabled electronic devices, such as Bluetooth, WiFi, 5G, and GPS-enabled devices.

• Bluetooth speakers
• Active RFID tags
• Smartphones
• Wireless microphones
• Wireless routers

Unintentional Radiators Examples

Unintentional radiators cover electronic devices that are not designed for wireless communications.

• LED Lighting
• Coffee machines
• USB sticks
• Wired mouses
• External switching power suppliers

Learn more

• FCC Electronics Regulation Guide For US Importers (Link)
• List of Products Covered by FCC Part 15: An Overview (Link)
• FCC Part 15 Supplier’s Declaration of Conformity (SDoC) Guide (Link)
• FCC Product Lab Testing: A Complete Guide (Link)
• List of FCC Lab Testing Companies: Our Top 9 Picks (Link)
• List of FCC Consulting Companies: Our 8 Top Picks (Link)

21 CFR (FDA)

21 CFR covers a wide range of products, including food contact materials, medical devices, cosmetics, and supplements – among others. That said, the specific lab testing, labeling, and certification requirements vary depending on the material and product type.

Food Contact Materials

21 CFR restricts heavy metals and chemicals in food contact materials, such as food packaging and kitchen utensils. It also covers the migration of elements, for example when microwaving a plastic food container.

Here are some provisions covering food contact materials:

• 21 CFR 174 – General Indirect Food Additives
• 21 CFR 175 – Adhesives and Components of Coatings
• 21 CFR 176 – Paper and Paperboard Components
• 21 CFR 177 – Polymers
• 21 CFR 178 – Adjuvants, Production Aids, and Sanitizers
• 21 CFR 179 – Irradiation in the Production, Processing, and Handling of Food

Third-party lab testing is often necessary in order to verify whether a food contact material is compliant – meaning that it does not contain or migrate restricted substances above the set limits.

Product Examples

Here are some examples of products defined as food contact materials:

• Kitchenware
• Tableware
• Cutlery
• Bottles
• Containers
• Food packaging
• Food additives

Learn more

• List of Products Covered by FDA Regulations: An Overview (Link)
• Food Contact Materials Regulations in the United States: An Overview (Link)
• FDA Product Lab Testing: A Complete Guide (Link)

Medical Devices

21 CFR also covers medical devices, ranging from sunglasses to pacemakers. Further, medical devices are classified as Class I, Class II, or Class III depending on the product. Notice that different requirements apply depending on the class.

Here are some examples:

• 21 CFR 807 – Establishment Registration and Device Listing for Manufacturers and Initial Importers of Devices
• 21 CFR 880.2920 – Clinical Mercury Thermometer
• 21 CFR 886.5850 – Sunglasses
• 21 CFR 801.410 – Drop Ball Test
• 21 CFR 801 – Labeling
• 21 CFR 830 – Unique Device Identification
• 21 CFR 814 – Premarket Approval of Medical Devices

Third-party lab testing is required in order to verify that the medical device complies with the specific requirements in the applicable 21 CFR part. Additional documentation and registration requirements can also apply.

Product Examples

• Sunglasses
• Glucose monitoring machine
• Pacemaker
• Contact lenses
• Breast implants
• Dermal fillers
• Personal protective equipment

Learn more

• Sunglasses & Eyewear Regulations in the United States (Link)
• Face Mask Regulations and Standards in the United States (Link)

Cosmetics

21 CFR applies to makeup and other cosmetic products sold in the United States. It sets restrictions on harmful chemicals, heavy metals, and other substances. Such substances include, but are not limited to, lead, arsenic, mercury, and chloroform.

Third-party lab testing is required in order to verify that the cosmetic product is safe and compliant with the substance restrictions. Additional documentation and registration requirements can also apply.

Product Examples

• Eyeliners
• Eye shadows
• Lipsticks
• Blush
• Concealer

Learn more

• Cosmetics Regulations in the United States: An Overview (Link)

Supplements

Dietary supplements are also regulated by 21 CFR, which includes vitamins, protein powder, herbal capsules, and more. More specifically, it covers ingredients, substance limits, good manufacturing practice (GMP), labeling, documentation, and testing requirements.

• 21 CFR 101.36 – Nutrition labeling of dietary supplements
• 21 CFR 111 – Current Good Manufacturing Practice for Dietary Supplements

Product Examples

• Vitamins
• Minerals
• Protein powder
• Herbal capsules
• Amino acids
• Enzymes

Learn more

• Supplement Regulations in the United States: An Overview (Link)

7 CFR 319.40 (Wooden Products)

7 CFR 319.40 covers US Department of Agriculture (USDA) Animal and Plant Health Inspection Service rules for wooden products, such as wooden furniture and crafts. Pre-import approvals are required for many products, which in turn specify whether the wooden product requires heat treatment or fumigation.

The ultimate aim is to eliminate the presence of pests in wooden products imported to the United States. In addition, the USDA APHIS also lists ‘approved’ wooden handicraft suppliers in China on their website.

Product Examples

• Baskets
• Boxes
• Bird houses
• Garden furniture
• Garden fencing and edging
• Picture frames
• Pens
• Pencils
• Wooden decorative collectibles
• Wooden kitchenware
• Other items composed of wood

Learn more

• Wood & Bamboo Product Regulations in the United States (Link)

Energy Policy and Conservation Act (EPCA)

The Energy Policy and Conservation Act (EPCA) sets requirements to assess energy usage, water usage, costs, and energy efficiency of electrical appliances.

Covered products must also bear a label that includes information such as efficiency rating, estimated yearly energy costs, and other information that is deemed to be useful for consumers.

Lab testing might be necessary to evaluate the consumption and energy efficiency of the products.

Product Examples

• Lighting Products
• Refrigerators
• Dishwashers
• Clothes washers
• Air conditioners
• Heaters

Learn more

Energy Policy and Conservation Act (Link)

Formaldehyde Emission Standards for Composite Wood Products

CFR Part 770 – Formaldehyde Emission Standards for Composite Wood Products was enacted by the EPA (Environmental Protection Agency) to limit the emission of formaldehyde caused by composite wood materials such as:

• Fiberboards
• Particleboards
• Plywoods

Besides restricting the amount of formaldehyde in covered products, the standards also include documentation and labeling requirements (e.g. producer’s name, lot number).

Lab testing is usually necessary to assess the amount of formaldehyde and ensure that it is not present in the products above the set limits.

Product Examples

• Furniture
• Accessories
• Toys
• Construction materials

Learn more

Formaldehyde Regulations in the United States: An Overview (Link)

Occupational Safety and Health Act (OSHA)

The Occupational Safety and Health Act (OSHA) covers safety requirements for industry-related items and personal protective equipment, such as workwear, safety goggles, N95 face masks, and protective shoes. More specifically, 29 CFR 1910 outlines general safety requirements for different product classes:

• 1910.132 – General Requirements
• 1910.133 – Eye and Face Protection
• 1910.134 – Respiratory Protection
• 1910.135 – Head Protection
• 1910.136 – Foot Protection
• 1910.137 – Electrical Protective Equipment
• 1910.138 – Hand Protection

Product & Testing Standards

The different parts listed above, in turn, references ASTM and ANSI standards applicable to certain product types and categories:

• ASTM F-2412 – Standard Test Methods for Foot Protection
• ANSI Z89.1 – American National Standard for Industrial Head Protection
• ANSI Z41 – American National Standard for Personal Protection – Protective Footwear
• ASTM D120-09 – Standard Specification for Rubber Insulating Gloves
• ANSI/ISEA 138 – Performance and Classification for Impact-Resistant Gloves

Third-party lab testing is often necessary for the sake of verifying that the product is compliant with the applicable ASTM and ANSI standards.

Further, OSHA also covers labeling and certification requirements.

Product Examples

• Eyes and face protective equipment
• Respiratory protective equipment
• Head protective equipment
• Feet protective equipment
• Hands protective equipment
• Electrical protective equipment

Learn more

• Occupational Safety and Health Act Guide for US Importers (Link)

Uniform Packaging and Labeling Regulation (UPLA)

The Uniform Packaging and Labeling Regulation has been adopted in 45 US states to cover packaging labeling requirements.

• Product name
• Net quantity (if applicable)
• Company name and identification (e.g. manufactured by)

Learn more

• Uniform Packaging and Labeling Regulation (UPLR) (Link)

Model Toxics in Packaging Legislation

The Model Toxics in Packaging Legislation is adopted in several US states and prohibits the usage of certain heavy metals in packaging materials. Such substances include lead, mercury, cadmium, and hexavalent chromium.

Product Examples

• Product packaging
• Cartons
• Packaging foam

Learn more

• Packaging Materials Regulations in the United States: An Overview (Link)

Bag Suffocation Warning

Bag suffocation warnings are mandatory in many US states. That being said, whether bag suffocation is required varies – but tend to be dependent on the following factors:

• Size of the bag opening
• Bag volume
• Bag dimensions
• Product type

Further, the specific warning labeling requirements, such as placement, may also differ. Here are some examples:

• Warning print on both sides of the bag
• Repeated warning texts (for larger bags)
• Warning print size

Example

This is a warning text example provided by Amazon:

Warning: To avoid the danger of suffocation, keep this plastic bag away from babies and children. Do not use this bag in cribs, beds, carriages, or playpens. This bag is not a toy.

Learn more

• Bag Suffocation Warning: What Importers & Amazon Sellers Must Know (Link)

California Proposition 65

California Proposition 65 restricts substances in consumer products sold in California. This includes, but is not limited to, the following substances:

• Lead
• Cadmium
• Mercury
• BBP
• DBP
• DEHP
• DIDP
• DINP
• DNHP

Third-party lab testing is often required in order to verify if a product or material contains any of the restricted substances above the set limits. Although there are exemptions, warning labeling is often required in case a product or material does contain restricted substances above the set limits.

Product Examples

• Apparel & Textiles
• Jewelry and Accessories
• Watches
• Toys
• Electronics
• Furniture
• Beauty & Care Products
• Stationery Accessories

Learn more

• California Proposition 65 Guide for US Importers & Amazon Sellers (Link)
• List of Products Covered by California Proposition 65 (Link)
• California Proposition 65 Product Lab Testing (Link)

US Law Label

Law labels are required in most US states for stuffed products such as sofas and furniture cushions. However, the specific labeling information required differs. Here are some examples that may be included in a law label:

• “Do Not Remove” Statement
• Filling materials (Weight %)
• Uniform Registry Number (URN)
• Company Name

Note that registration is required in order to obtain a Uniform Registry Number (URN).

Product Examples

• Baby carriers
• Bean bags
• Car seat protectors
• Sleeping bags
• Sofas
• Stuffed toys
• Furniture cushions
• Kids car seats

Learn more

• US Law Label Requirements For Importers (Link)