The Legal Foundation
The Children's Product Certificate requirement comes from Section 14(a) of the Consumer Product Safety Improvement Act of 2008 (CPSIA), codified at 15 U.S.C. 2063(a). The law states that every manufacturer or private labeler of a product subject to a consumer product safety rule must certify that the product complies with all applicable rules, bans, standards, and regulations.
For children's products specifically, Section 14(a)(2) imposes stricter requirements: certification must be based on testing by a CPSC-accepted third-party laboratory, and the certificate must include specific data elements that go beyond what is required for general-use consumer products.
The 7 Required Elements in Detail
CPSIA Section 14(a)(2)(B) specifies seven categories of information that every CPC must contain. Here is each one, with the level of detail needed to satisfy CPSC requirements.
Identification of the product
The certificate must describe the product in enough detail to identify it. This means a product name, model or SKU number, and any distinguishing characteristics. "Children's toy" is not sufficient. "Wooden building blocks set, Model WBB-50-NAT, 50 pieces, intended for ages 3+" is.
If one certificate covers multiple products (a product line with the same construction and materials tested together), each product should be identifiable.
Citation of each applicable children's product safety rule
List every CPSC rule, ban, standard, or regulation that applies to the product. Use the official citation (e.g., "ASTM F963-23" or "16 CFR 1501"). Common applicable rules include:
- ASTM F963 — Toy safety standard (for all toys)
- CPSIA Section 101 — Lead content limit (100 ppm for substrate, applies to all children's products)
- CPSIA Section 108 — Phthalate limits (applies to toys and child care articles)
- 16 CFR 1303 — Lead paint ban (90 ppm, all children's products with paint/coatings)
- 16 CFR 1501 — Small parts (products for children under 3)
- 16 CFR 1610 — Textile flammability (children's clothing)
- 16 CFR 1615/1616 — Children's sleepwear flammability
If a rule applies but your product qualifies for an exemption or a determination of applicability, you may note that on the certificate with the citation for the exemption.
Identification of the domestic manufacturer or importer certifying compliance
The certificate must identify the party issuing it: either the U.S. domestic manufacturer or the U.S. importer of record. Include the full company name, street address, and contact information (phone and/or email).
Only these two parties can legally issue a CPC. A foreign manufacturer, trading company, or freight forwarder cannot be the certifier.
Contact information for the person maintaining test records
Identify the person or entity that maintains the test records supporting the certificate. This is often the same as the certifier, but it can be a different department, agent, or third party. Include name, address, phone, and email.
CPSC uses this information when they need to review your testing documentation during an investigation or audit.
Date and place of manufacture
State when and where the product was manufactured. For a production run, include the month/year range. The place should include at minimum the city and country. Including the state or province is recommended for clarity.
Date and place where product was tested
The date and location where third-party testing was performed. This should reflect the actual testing dates from your lab reports, not the date you received results or created the certificate. Include the city and country of the testing facility.
Identification of the third-party testing laboratory
For each lab that tested the product, provide:
- Full laboratory name
- Street address
- Telephone number (required per 16 CFR 1110.11)
- CPSC-accepted laboratory identification number
If different standards were tested at different labs, identify which lab tested which standards. Verify lab acceptance at cpsc.gov/labsearch.
Generate a CPC with all 7 elements properly formatted
Open the Free CPC GeneratorCommon Compliance Mistakes
- Listing the foreign factory as certifier. The certifier must be the U.S. importer or domestic manufacturer — not the overseas factory, even if the factory performed the testing coordination.
- Missing lab phone number. 16 CFR 1110.11 requires the lab's telephone number. Many templates omit this field.
- Using an expired or non-accepted lab. Lab acceptance can change. Always verify current acceptance status before creating a new CPC.
- Omitting applicable safety rules. Every applicable rule must be listed. Missing lead content limits on a children's product is a common oversight.
- Vague product identification. "Toy" or "children's product" is not specific enough. Include model numbers, product names, and distinguishing characteristics.
- No date of manufacture. The manufacturing date is required even if it seems redundant with the testing date. They serve different purposes.