January 20, 2026

Children’s Product Certificate (CPC): Requirements & Guide

A Children’s Product Certificate (CPC) is a written compliance certificate required for children’s products that are subject to applicable U.S. children’s product safety rules. A children’s product is generally a consumer product designed or intended primarily for children 12 years of age or younger.

For products that require third-party testing, the CPC is generally based on passing test results from a CPSC-accepted third-party laboratory. The certificate identifies the product, applicable safety requirements, manufacturing and testing information, and the laboratory involved in the testing.

The testing laboratory provides the test results. The responsibility for issuing the CPC remains with the domestic manufacturer or importer, depending on where the product is manufactured.

What is the Purpose of a Children’s Product Certificate?

A CPC provides documented certification that a children’s product complies with the applicable safety rules enforced by the U.S. Consumer Product Safety Commission (CPSC).

The certificate connects the finished product with its applicable safety requirements and supporting compliance information.

A CPC may be required to accompany shipments of regulated children’s products and must be available to the CPSC and U.S. Customs and Border Protection when required. Electronic certificates can also satisfy the accompanying requirement when the applicable CPSC conditions are met.

A CPC is not a laboratory test report or product approval issued by the CPSC. It is a certification document prepared using the applicable compliance information and supporting test results.

When is a CPC Required?

A CPC is required when a product:

Qualifies as a children’s product, generally meaning it is designed or intended primarily for children 12 years of age or younger; and
Is subject to one or more applicable children’s product safety rules, bans, standards, or regulations enforced by the CPSC.

Children’s products subject to these requirements generally require third-party testing and certification. Certain exemptions, exceptions, determinations, and testing relief provisions may apply to specific products, materials, or manufacturers.

Factors used when evaluating whether a consumer product is a children’s product can include its intended use, design, packaging, marketing, age grading, and how consumers commonly recognize and use the product.

The applicable requirements therefore need to be determined according to the specific product and its intended users.

Who Issues the CPC?

The CPC is issued by the party legally responsible for certification.

For products manufactured outside the United States, the importer is generally responsible for issuing the CPC. For products manufactured within the United States, the domestic manufacturer is responsible.

A testing laboratory, consultant, supplier, or other third party may assist in preparing the certificate. However, the domestic manufacturer or importer remains legally responsible for the CPC and the accuracy of its information.

This distinction is important because a CPSC-accepted laboratory conducts the required testing and issues the test report, while the responsible manufacturer or importer issues the Children’s Product Certificate.

Products That May Require a CPC

Many different categories of children’s products can fall within CPC requirements when they are subject to applicable CPSC safety rules.

Examples may include:

Toys and games
Plush toys
Infant and baby products
Childcare articles
Children’s clothing
Children’s furniture
Children’s jewelry
Ride-on toys
Educational products
Certain school supplies
Cribs, bassinets, and other regulated nursery products

The product category alone does not determine the complete certification requirements. Product design, materials, age grading, intended use, and applicable CPSC regulations all need to be considered.

What Information Must Be Included in a CPC?

The CPSC does not require companies to use one specific CPC template. However, the certificate must contain the required information and accurately identify the product being certified.

A CPC contains seven required elements.

1. Product Identification

The certificate must describe the product clearly enough to identify the item covered by the certification.

This may include information such as:

Product name
Model number
SKU
Style number
Product description
Other relevant product identifiers

2. Applicable Safety Rules

The CPC must identify each applicable children’s product safety rule for which the product is being certified.

The exact requirements depend on the product.

3. Certifying Party Information

The certificate must identify the domestic manufacturer or importer responsible for certifying the product.

Required information may include the company name and relevant contact details.

4. Test Record Contact Information

The CPC must provide contact information for the individual maintaining the supporting test records.

5. Date and Place of Manufacture

The certificate must identify when and where the product was manufactured.

The CPSC requires at least the month and year of manufacture, together with the applicable manufacturing location information.

6. Date and Place of Testing

The certificate must identify the applicable test dates or test report dates and the locations where testing was conducted.

7. CPSC-Accepted Laboratory Information

Where third-party testing is required, the CPC must identify the CPSC-accepted laboratory that conducted the testing.

The required laboratory information includes details such as the laboratory name, mailing address, and telephone number.

What Safety Requirements May Apply to a CPC?

There is no single test program that applies to every children’s product.

The required testing depends on factors such as:

Product type
Materials
Components
Intended age group
Product function
Potential hazards
Applicable CPSC regulations

Common requirements may include:

Requirement	Typical Application
CPSIA lead requirements	Lead content and lead in surface coatings
CPSIA phthalates requirements	Certain toys and childcare articles containing accessible plasticized materials
ASTM F963	Toys intended for the U.S. market
16 CFR requirements	Product-specific CPSC regulations
Flammability requirements	Certain textiles and other regulated products
Durable infant product standards	Specific nursery and infant products

For toys, ASTM F963 is particularly important because applicable provisions of the standard form part of the mandatory U.S. toy safety framework.

A product may be subject to several requirements at the same time.

CPC vs CPSIA

CPC and CPSIA are closely connected, but the terms describe different parts of the U.S. children’s product compliance system.

CPC	CPSIA
Children’s Product Certificate	Consumer Product Safety Improvement Act
Compliance certificate	Federal legislation
Issued by the responsible domestic manufacturer or importer	Establishes and strengthens children’s product safety requirements
Identifies applicable safety rules	Includes requirements relating to testing, lead, phthalates, tracking labels, and other areas
Supported by applicable compliance evidence	Provides part of the legal framework governing children’s products

The CPSIA establishes important safety and testing requirements for children’s products. The CPC documents certification to the applicable children’s product safety rules.

CPC vs ASTM F963

ASTM F963 and CPC are also commonly confused because both frequently apply to children’s toys.

CPC	ASTM F963
Compliance certificate	Toy safety standard
Covers applicable safety rules for the certified product	Establishes technical safety requirements for toys
Issued by the responsible domestic manufacturer or importer	Contains requirements and test methods for toy hazards
Prepared using applicable compliance information	Used when evaluating toys against applicable safety provisions

ASTM F963 addresses areas such as mechanical hazards, small parts, accessible edges and points, certain chemical requirements, and other toy-related hazards.

When ASTM F963 requirements apply to a toy, the relevant requirements form part of the compliance basis referenced by the CPC.

Testing Required Before Issuing a CPC

Children’s products subject to applicable safety rules generally require testing by a CPSC-accepted third-party laboratory.

The specific test program depends on the product.

Testing may include:

Mechanical and physical testing
Small parts testing
Lead content testing
Lead in paint or surface coating testing
Phthalates testing
Flammability testing
Product-specific structural testing
Electrical testing where applicable
Applicable ASTM F963 testing for toys

Certain products, materials, or manufacturers may qualify for specific testing exemptions, determinations, or testing relief. A CPC may still be required even where a particular third-party testing requirement does not apply.

For products with multiple materials or components, component part testing may also be used under certain conditions. Existing supplier test reports or certifications can sometimes support certification when the applicable requirements under 16 CFR part 1109 are satisfied and appropriate due care is exercised.

How to Get a Children’s Product Certificate

Obtaining a CPC requires several compliance steps before the certificate can be prepared.

Step 1: Determine Whether the Product Is a Children’s Product

Confirm the intended age group and whether the product falls within the CPSC definition of a children’s product.

Step 2: Identify the Applicable Safety Rules

Determine which CPSC-enforced requirements apply to the specific product.

A toy, for example, can be subject to ASTM F963 requirements, CPSIA chemical restrictions, tracking label requirements, and other applicable provisions.

Step 3: Determine the Required Testing

Create the test scope according to the product type, materials, age grading, design, and applicable regulations.

For complex toys, the required testing can vary considerably according to their components and functions. A structured assessment of which toy safety tests are required can help define the appropriate test scope.

Step 4: Use a CPSC-Accepted Laboratory

Where third-party testing is required, samples must be tested by a laboratory accepted by the CPSC for the applicable test methods.

A laboratory’s acceptance should cover the specific CPSC requirements being tested.

Step 5: Review the Test Results

Confirm that the product has passing results for the applicable requirements and that the test reports correctly identify the tested product.

Step 6: Prepare the CPC

Using the supporting compliance information, prepare the certificate with all required elements.

The CPSC does not charge a fee to create a CPC, and companies are not required to purchase a CPC from a laboratory or consultant.

Step 7: Maintain the Certificate and Supporting Records

The certificate and underlying test documentation should remain traceable to the certified product, production information, and applicable shipments.

CPC eFiling Requirements for Imported Products

An important change to CPSC certification requirements took effect on July 8, 2026.

Importers of consumer products subject to CPSC certification requirements must electronically file the required certificate data with U.S. Customs and Border Protection through the Partner Government Agency (PGA) Message Set.

For imported products entering from a Foreign Trade Zone, the applicable effective date is January 8, 2027.

The eFiling requirement affects imported products that require CPSC certification, including children’s products requiring a CPC.

This means CPC compliance for applicable imports now includes both the underlying product certification requirements and electronic submission of the required certificate data during the import process.

Is a CPC Required for Every Shipment?

Yes. CPSC guidance states that each imported or domestically distributed shipment requiring certification must be accompanied by the required certificate. The certificate can accompany the shipment electronically when the applicable requirements are satisfied.

This does not necessarily mean a completely new CPC must always be created for every identical production batch.

Where subsequent shipments remain materially unchanged, one CPC may cover multiple batches or lots when the certificate properly identifies the products covered and appropriate due care has been exercised to ensure continued compliance.

When Does a CPC Need to Be Updated?

Changes to a children’s product can affect the validity of existing test results and certification.

A material change may include changes to:

Product design
Manufacturing process
Component materials
Component suppliers
Manufacturing facility
Other factors that could affect compliance

When a material change could affect compliance with an applicable children’s product safety rule, the affected product or component must be tested as required by a CPSC-accepted laboratory. A new CPC must then be issued based on the applicable passing test results.

For example, changing the paint supplier for a painted toy may require new testing for requirements affected by the paint change. The scope of retesting depends on how the change affects the product’s compliance.

Changing the manufacturer can require retesting and recertification because the manufacturing facility, equipment, processes, and process controls may affect product compliance.

Periodic Testing for Children’s Products

Initial testing may not be the final testing obligation for products that remain in continuous production.

CPSC regulations require periodic testing for applicable children’s products in continuing production. The testing frequency depends on the testing approach and controls used by the manufacturer.

Periodic testing helps provide continued assurance that products remain compliant after initial certification.

Short production runs can be treated differently under the applicable requirements, although material changes can still trigger retesting and a new CPC.

Common CPC Compliance Mistakes

Several problems can lead to incomplete or inaccurate children’s product certification:

Using Children’s Product Certification as if it were the official name of the certificate
Assuming every children’s product follows the same testing requirements
Using a laboratory that is not CPSC-accepted for the applicable test scope
Leaving applicable safety rules off the CPC
Providing incomplete manufacturing or testing information
Treating the laboratory test report as the CPC
Assuming the testing laboratory is legally responsible for issuing the CPC
Using outdated test reports after a material product change
Failing to evaluate changes in materials, components, suppliers, or manufacturing processes
Failing to address applicable CPSC eFiling requirements for imported products

A CPC should accurately correspond with the product and supporting compliance evidence.

What Happens If a CPC Is Missing or Incorrect?

Failure to comply with applicable CPSC testing and certification requirements can lead to regulatory and commercial consequences.

Potential issues include:

Customs clearance problems
CPSC enforcement action
Product detention or import problems
Product recalls
Retailer or marketplace rejection
Additional testing or documentation requests
Civil penalties where applicable

Issuing a materially false or misleading certificate can also result in CPSC enforcement.

CPC compliance depends on accurate product classification, identification of applicable CPSC safety rules, appropriate testing, and complete certification records.

Changes to product design, materials, component suppliers, manufacturing processes, or manufacturing locations should be reviewed to determine whether they constitute a material change requiring additional testing and a new CPC. Products in continuing production may also be subject to periodic testing requirements.

For imported products subject to CPSC certification requirements, the applicable certificate data must also be prepared for CPSC eFiling requirements effective July 8, 2026. Keeping testing, certification, and shipment information aligned helps maintain a clear compliance record throughout production and importation.

Frequently Asked Questions

1. Who issues a CPC?

The manufacturer or U.S. importer issues the CPC based on valid third-party laboratory test reports.

2. Does every toy require a CPC?

Most toys intended for children aged 12 years or younger require a CPC before they can be sold in the United States.

3. Can I issue a CPC without testing?

No. Most children’s products require testing by a CPSC-accepted laboratory before a CPC can be issued.

4. Is a CPC the same as a laboratory test report?

No. A laboratory test report provides testing results, while a CPC is the manufacturer’s or importer’s declaration that the product complies with all applicable regulations.

5. Does a CPC expire?

A CPC does not have a fixed expiration date. However, it should be updated whenever the product, materials, manufacturing process, or applicable regulations change.