• Wooden Toys Regulations in the United States: An Overview

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    Wooden Toys Regulations in the United States

    Planning to import, export or manufacture wooden toys in the United States? In this guide, we cover the basics of product regulations, labeling, testing, standards, and certification requirements applicable to toys and wooden products.

    Mentioned Products

    • Wooden trains
    • Wooden dolls
    • Burr puzzles
    • Wooden educational toys
    • Wooden puzzles
    • Other wooden children’s products

    CPSIA

    The Consumer Product Safety Improvement Act first came into effect in 2008 and specifically aims at regulating chemical substances within children’s products, such as toys for children below 12 years, manufactured, imported and sold in the US market. Below is a list of matters needing attention regarding CPSIA regulation.

    ASTM Standards

    ASTM, the American Society for Testing and Materials, is an international standards organization that seeks to develop voluntary consensus technical standards for a wide range of materials and products, for the purpose of improving the quality of the general products in the US market.

    CPSIA requires that all the wooden toy products manufactured, imported and sold in the US market must be fully compliant with the applicable ASTM standards.

    Examples

    • ASTM F963-17 Standard Consumer Safety Specification on Toy Safety
    • ASTM F834-84 (2008) Consumer Safety Specification for Toy Chest
    • ASTM F1148-09 Standard Consumer Safety Performance Specification for Home Playground Equipment

    Learn more

    You can learn more about relevant ASTM standards and rules on this page.

    Risks

    ASTM standards cover both substance restrictions and mechanical/physical safety aspects. Toys manufactured outside the United States are not necessarily compliant with CPSIA and ASTM standards. For example,  paints, wood finishes, and print inks may contain excessive amounts of lead, cadmium and other restricted substances. Likewise, compliance with physical and mechanical safety aspects should not be taken for granted.

    It’s therefore essential to verify the suppliers existing compliance track record, in the form of test reports.

    CPSIA Testing

    Before you import wooden toy products to the US market, make sure your products are compliant with all applicable federal or state regulations. Therefore, always have your wooden toy products lab-tested by a CPSC (Consumer Product Safety Commission) approved lab-testing company.

    You must take the sample that the laboratory tests from the production run of the exact product you are importing, not from any similar product.

    In most cases, when you request a quotation from a CPSC testing company, the company will, at no additional charge, also help you to determine which ASTM and CPSC standards are applicable to your product.

    List of CPSC approved testing companies

    • Bureau Veritas
    • QIMA
    • SGS
    • TUV
    • Intertek

    Click here for more CPSC approved testing companies.

    CPSIA Testing Costs

    The cost of CPSIA lab-testing reports is at least $300 but can be much higher depending on the individual company and the product.

    Learn more

    You can read more about CPSIA and ASTM lab testing in this guide.

    Children’s Product Certificate (CPC)

    The CPC, short for Children’s Product Certificate, is a document that is required by law to self-draft by the importer or the manufacturer, in the language of English, based upon the passing test results of third-party testing companies that approved by the CPSC (US Consumer Product Safety Commission). CPC certifies that a product is compliant with the applicable safety regulations.

    Here is a list of information you should consider including in your CPC:

    Content Summary

    1.Product name and description (e.g. Wooden Puzzle)

    2. List of applied and mandatory ASTM and CPSC standards (e.g ASTM F963)

    3. Importer information (name, address, e-mail, phone)

    4. Contact information of the person with access to the test report (name, address, e-mail, phone)

    5. Manufacturing location (city, province, country) and date (month, year)

    6. Testing date (month, year) and location (city, province, country)

    7. CPSC accepted third-party lab testing company (company, contact person, address, phone, e-mail)

    Learn more

    This guide explains the steps to create a CPC when importing wooden toy products and other children’s products.

    CPSIA Tracking Label

    A CPSIA tracking label is mandatory to be carried by your wooden toy products (primarily products used by ages 12 or younger children). Below is some information you should cover on the tracking label:

    • Importer company name
    • Production location
    • Production date
    • Batch number

    Note that you must affix the tracking label to your wooden toy products and its packaging.

    Example

    • Wooden Trains LLC
    • Production Location: Nantong, China
    • Production Date: May 2020
    • Batch Number: XC01-03340-NT-CN

    Label file

    Generally, you should prepare the tracking labels for your products, as it is not a service covered by the supplier. The tracking label should be a print-ready version of the document with all the required information. Here follows an example:

    • Country of Origin
    • Dimensions
    • Colors
    • Print type

    CPSIA Consumer Registration Cards

    Some baby/children toys are required to enclose a registration card when selling in the market, such as durable infant or toddler products. A registration card helps customers to report safety issues of the products and also easy for you to manage product recalls.

    Regarding the label requirements for children’s products, click here for more detailed explanations.

    Registration card requirements

    • Postage-paid to a US address
    • Model number
    • Manufacture date
    • Importer name
    • Website
    • US address
    • US phone number (Toll-Free)

    Wooden Product Regulations

    The United States Department of Agriculture Animal and Plant Health Inspection Service (USDA APHIS) sets standards for wooden products.

    In the following section, we summarize the key regulations covering this class of wooden products in the US.

    Approved Suppliers

    The government of the People’s Republic of China maintains a list of all Chinese wooden handicraft suppliers that meet qualifications set through an agreement with USDA APHIS. You will need to select your manufacturer from this list.

    Facility Requirements

    These mutually accepted conventions cover facility sanitation, pest control, materials quarantine, traceability, fumigation, and heat treatment requirements:

    • All wood used is heat-treated or fumigated.
    • The workspace meets basic sanitation standards.
    • Wood is quarantined until it has been treated.
    • The company implements pest control strategies throughout the workspace.
    • The company implements an acceptable traceability scheme for all products.
    • The company implements appropriate quality control measures.

    Pre-Import Approvals

    Once you can show that you are working with an APHIS-approved supplier, you may apply for an import permit on the ePermits website.

    The first step of this process is to register for a USDA eAuthentication account on the USDA’s website. Second, you will need to upload the information needed for the application:

    • The categories of products you are importing
    • The registration number of the manufacturer
    • Your contact information
    • Quantity of goods to be imported

    After submitting the application, you can return to the website to check on its status. Barring complications, you should receive your permit in about 30 days.

    Permit

    Each permit pertains to wood products requiring a particular type of treatment, including fumigation and/or heat treatment.

    You will also need to fill out a declaration form for each planted or natural forest from which you source your wood.

    This form includes the following items:

    • The tree’s scientific name
    • The country where it was harvested
    • The cost of the wood
    • General description of the qualities of the wood

    Learn more

    See the official USDA website to find approved suppliers, review facility and wood treatment requirements, obtain the pre-import approval forms, and learn about the process in more detail.

    California Proposition 65

    The California Office of Environmental Health Hazard Assessment (OEHHA) annually updates the list of chemicals that are restricted by California Proposition 65 as they are known to cause cancer or other defects of the human body.

    Currently, the proposition lists more than 800 kinds of toxic or dangerous chemicals ever since it was first launched in 1986. It requires that all the products manufactured or imported to the state of California must be compliant with the limits imposed on restricted substances, and it also covers wooden toy products.

    Examples of restricted substances

    • Lead
    • Cadmium
    • Mercury
    • Phthalates

    California Proposition 65 Lab testing

    As said, California Proposition 65 covers many restricted or prohibited chemical substances used in consumer products, and this list is still updating and expanding each year.

    In order to avoid all the troubles caused by selling incompliant products, we strongly suggest that all the wooden toy products importers conduct lab testing reports for your products according to the requirements of the standards.

    Accredited third-party lab testing companies generally offer complete and integrated chemical testing services. This is a typical procedure before you have your wooden toy products are imported to the US market.

    Kindly note that most of the wooden toy manufacturers in China and Southeast Asia are not able to provide the California Proposition 65 Lab test reports.

    Testing costs

    The cost of California Proposition 65 lab-testing reports is at least $200 but can be much higher depending on the individual company and the product.

    Testing companies

    Click here for a list of companies offering California Proposition 65 lab testing services.

    Warning Labeling

    Testing is not mandatory for complying with California Proposition 65. You can either choose to attach a warning label to your product or packaging or verify that your wooden toy products don’t contain any restricted substances above the limits set by the proposition, via a lab test.

    Country of Origin

    Attaching a Country of Origin label is mandatory in many countries in the world, including the United States. Therefore, always make sure your wooden toy products contain a permanently affixed label indicating the country of origin.

    Examples

    • Made in China
    • Made in Vietnam
    • Made in Mexico
    • Made in the USA

    Label file

    In order to make the communication between you and the manufacturers easier, we suggest that you create a file for your relevant label documents and share it with your manufacturer before starting mass production. We recommend that you use .ai or .eps formats for your file.

    Product Packaging

    Other than the main product, importers and manufacturers must also ensure that the packaging materials are 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 adhere to these standards, you must contract with a third-party laboratory testing company such as Bureau Veritas, TUV, or QIMA.

    Labeling Requirements

    You may also be required that the packaging prominently display any applicable compliance marks and/or country of origin along with other labels.

    Amazon Compliance Requirements

    Amazon requires that all the products sold in its platform be compliant with all applicable regulations, whether they are set at the federal or state level. Sellers must ensure that their products had acquired all the required documents and certificates.

    Therefore, it’s essential that you carefully read the relevant product category requirements in the Amazon Seller Central before you intend to import and sell the wooden toy products.

    How does Amazon check product compliance?

    As mentioned above, Amazon sellers must provide all required lab test reports, certificates, product photos, and invoices upon Amazon’s request, which might come at any time.

    What can happen if we sell non-compliant wooden toy products on Amazon?

    Amazon may remove any product listing at its own discretion. While they usually only remove individual SKUs, they may opt to remove all your listings or suspend your account.

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    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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