What is Children’s Product Certification (CPC)

Children’s Product Certification, commonly referred to as CPC, is a legally required compliance document under United States federal law for products that are designed or intended primarily for children aged 12 years or younger. It is mandated by the Consumer Product Safety Commission (CPSC) and established under the Consumer Product Safety Improvement Act (CPSIA)

A CPC is a written declaration issued by the responsible party, typically the manufacturer or the importer of record, confirming that a children’s product complies with all applicable US safety regulations. These regulations may include chemical restrictions, mechanical safety requirements, labeling obligations, and other mandatory rules enforced by the CPSC.

A CPC serves a specific legal function. It is not a test report, a product label, a logo, or a marketing claim. It is a mandatory compliance declaration that confirms a children’s product meets all applicable US safety regulations.

This distinction is essential. Laboratories produce test reports. Companies issue CPCs. The CPC references the test reports, but it does not replace them.

The CPC framework is based on legal accountability. When a company issues a CPC, it is making a formal statement that it understands which regulations apply to its product and that it has obtained valid evidence of compliance. If that statement is false, incomplete, or unsupported by proper testing, the company may face enforcement actions.

In practical terms, a CPC is required before a children’s product can be legally sold, imported, or distributed in the United States. It applies to physical retail, online sales, wholesale distribution, and promotional use.

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When a CPC Is Required

A CPC is required for any product that qualifies as a children’s product under US law.

A children’s product is defined as a consumer product designed or intended primarily for children aged 12 years or younger. This classification is not based on a single factor. The CPSC evaluates several criteria when determining whether a product falls under the children’s product category:

• The product’s stated intended use
• Age grading on packaging or instructions
• Marketing materials and promotional language
• Product design features
• Common consumer perception
• Reasonably foreseeable use

If a product is reasonably expected to be used by children under 12, it is likely to be considered a children’s product, even if adults also use it.

Examples of products that typically require a CPC include:

• Toys and games
• Baby and toddler products
• Childcare articles
• Children’s furniture
• Feeding and nursing accessories
• Educational and learning tools
• School supplies
• Children’s jewelry
• Play equipment

CPC requirements apply regardless of whether the product is sold online or offline, imported or domestically manufactured, or distributed through retailers, marketplaces, or direct-to-consumer channels.

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Common Misclassification Issues

Misclassification is one of the most frequent compliance failures in the US children’s product sector.

Many companies assume a product does not require a CPC because:

• It is marketed as educational rather than as a toy
• It is decorative rather than functional
• It is sold as a gift item
• Adults also use it
• It does not look like a traditional toy

None of these assumptions automatically remove CPC obligations.

If the product is designed or marketed for children, or if children are the primary intended users, it will typically fall under the CPC framework.

Another common mistake is assuming that a product tested for another market automatically qualifies for US compliance. This is incorrect. US compliance is market-specific. Testing performed for European standards, such as EN71, does not satisfy CPC requirements.

The CPC system is based on US federal law. Only US-recognized standards and rules apply.

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What a CPC Certifies

A CPC does not certify a product category. It certifies compliance.

This means it confirms that a specific product meets every applicable safety regulation enforced by the CPSC.

The exact scope of what must be listed on a CPC depends on the product type, materials, design, and intended use. There is no universal CPC template that fits all products.

However, most children’s products must comply with CPSIA, which establishes:

• Limits on lead content in substrates
• Limits on lead in surface coatings
• Bans on certain phthalates
• Third-party testing obligations
• Tracking label requirements

For toys, CPCs usually include compliance with ASTM F963, the mandatory US toy safety standard. ASTM F963 covers:

• Mechanical and physical hazards
• Small parts and choking risks
• Sharp edges and points
• Impact and drop resistance
• Flammability
• Sound-producing components
• Labeling and warning requirements

Depending on the product type, additional CPSC rules may apply, such as:

• Pacifier safety requirements
• Crib and toddler bed standards
• Stroller regulations
• Children’s jewelry rules
• Electrical toy safety provisions

A valid CPC must list all applicable regulations. A generic or incomplete certificate is legally invalid.

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CPC vs CPSIA

CPC and CPSIA are closely related but serve different roles.

CPSIA is the law. It establishes the safety rules, chemical limits, testing obligations, and enforcement authority.

CPC is the legal declaration. It is how a company formally states that it complies with CPSIA and any other applicable CPSC regulations.

CPSIA defines what must be done. CPC declares that it has been done.

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CPC vs ASTM F963

ASTM F963 is a technical safety standard. It explains how toys must be designed and tested to address specific hazards.

CPC is a legal document.

For toys sold in the US:

• ASTM F963 defines how the toy is tested
• CPSIA defines the legal requirements
• CPC declares that the toy complies with both

ASTM F963 does not replace CPC. CPC does not replace ASTM F963 testing. They work together but serve different purposes.

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Testing Requirements Behind a CPC

A CPC must be supported by valid third-party testing conducted by a CPSC-accepted laboratory.

Self-testing by the manufacturer is not sufficient for most children’s products.

Testing typically includes:

• Mechanical and physical safety testing
• Chemical analysis for lead and phthalates
• Flammability testing, where applicable
• Durability and abuse testing
• Labeling and warning verification

The exact test scope depends on:

• Product materials
• Structural design
• Intended age group
• Foreseeable use
• Hazard profile

Testing must be representative of the product being sold. If a product has multiple colorways, materials, or production batches, this may affect the required test scope.

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Consequences of Non-Compliance

Selling a children’s product without a valid CPC can result in:

• Import detentions
• Customs clearance failures
• Marketplace takedowns
• Mandatory recalls
• Civil penalties
• Public enforcement actions
• Reputational damage

The CPSC has authority to request CPCs and supporting test reports at any time. Failure to produce them may trigger investigations.

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Children’s Product Certification depends on proper testing, accurate rule identification, and complete documentation. Because every toy differs in materials, structure, and intended use, testing scopes and costs can vary significantly. To determine the appropriate test scope and obtain a preliminary cost estimate, use our Toy Testing Calculator.