CPSC stands for the Consumer Product Safety Commission. The Commission’s job is to set standards and requirements for children’s products, including materials and labelling.
If you are a US based maker of children’s clothing, toys or accessories you will need to ensure that your business is compliant with the rules set out by the CPSC. If you are a non-US based manufacturer and would like to sell to US customers, then you will also need to ensure that you are compliant.
An important note is that CPSC compliance applies to all businesses no matter the size: if you are just making the one doll to sell on Etsy or donating to a charity you will still need to ensure that your products are as compliant as possible.
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CPSIA
In 2008 Congress passed the Consumer Product Safety Improvement Act (CPSIA) - this act states that all manufacturers must:
- pay a qualified lab to test and certify any product intended for children (otherwise known as a “third party test”) and;
- label all relevant products accurately in case of a recall.
How to register for CPSC
The first step is to register for the SPSC Business Portal - this allows you to receive reports of safety complaints on products and materials, and also enables you to fulfil your obligations to report safety issues that have been reported via your customers.
The Small Batch Manufacturer exemption
For businesses with total gross revenue of $1,123,530 or less in the last calendar year AND with no more than 7,500 units created of a product under CPSC jurisdiction it is possible to register as a “Small Batch Manufacturer” and thus gain an exemption from the requirement of lab testing your raw materials.
If you meet the requirements above, you should identify yourself on the CPSC’s Small Batch Manufacturers Registry to obtain a registration number. You must register as a Small Batch Manufacturer every year to qualify for this testing relief, so you won’t want to put this number onto any labelling as it will change.
Note: There are some products that will require testing regardless of your manufacturer status (known as Group A) this includes things like cribs, baby walkers / jumpers and metal jewelry.
Small Batch Manufacturers are however still required to document and certify that all products they make are made using compliant materials - this is via the creation of Product Certificates (we’ll cover this in detail below).
For every material you use to create your products, you will need to ensure that these meet with CPSC guidelines for things like lead, BPA and phthalate content (amongst others). You can do this by ensuring that you research and obtain the CPSC testing certificates from the vendors you purchase your materials from and ensuring that you track your inventory usage accurately so that you are aware of the exact materials used in every product you sell.
Children’s Product Certificates (CPC)
Another requirement that you’ll need to be aware of for CPSC compliance is the creation of Children’s Product Certificates (otherwise known as CPCs).
This is a document that you need to create for each of your products that outlines the key details required to certify the product from a CPSC perspective.
See our blog post covering how to create a Children’s Product Certificate (CPC) for details on the requirements, along with a sample certificate.
CPSC Labelling
In addition to documenting your manufacturing and material usage, you’ll also need to ensure that your labels meet with the standards required. The actual requirements vary depending on the product, however all children’s products need to have a permanently attached label (with the exemption of very small items or certain reversible garments in which a hang-tag may be acceptable).
Your care label also needs to contain at a minimum:
- The manufacturer of the item (this would be your business name and logo)
- How you can be contacted (email, phone or website)
- Where you are creating the product (city and state, also country if you ship internationally)
- When the product was finished (month and year)
- Fiber content (if applicable)
- How to care for the product
- Manufacture batch ID (to enable traceability for recalls)
Do I need to test my manufactured products for CPSC compliance?
Most small craft businesses based in the US are eligible to claim for CPSC testing relief for their products.
This relief, called the Small Manufacturers Exemption, basically means that you (in most cases*) will not have to conduct or pay for your own lab testing to comply with the CPSC. Instead, you can rely on the lab testing already performed by your vendors - to do this, contact each of your suppliers and ask them for their CPSC-approved lab tests for each material you use to produce your products. Keep in mind that some international testing standards such as EN (European) or OEKO-Tex may not be sufficient for CPSC, so you’ll want to ensure that they are CPSC-approved.
From here you need to document the tests along with detailed product information to create Product Certificates for each of your products.
Eligible businesses for the small manufacturer exemption are those with total gross revenue of no more than $1,123,530 in the last calendar year AND with no more than 7,500 units created of a product under CPSC jurisdiction.
If you meet the requirements above, you should firstly identify yourself on the CPSC’s Small Batch Manufacturers Registry to obtain a registration number.
Note: You must register as a Small Batch Manufacturer every year to qualify for this testing relief, so you won’t want to put this number onto any labelling as it will change.
*There are also some products that will require direct testing regardless of your manufacturer status (known as Group A) this includes things like cribs, baby walkers / jumpers and metal jewelry.
