In this article
The short answer
A Children's Product Certificate (CPC) is a written certificate issued by the US importer of a foreign-made children's product, or by the domestic manufacturer of a US-made one, stating that the product complies with every applicable CPSC children's product safety rule. It must rest on passing tests from a third-party laboratory that the CPSC has accepted for each rule you cite. The CPSC does not test, approve or stamp the product. Since 8 July 2026 the rewritten 16 CFR Part 1110 applies: certificate content has been updated for everyone, and importers must eFile certificate data with CBP at entry. Amazon and most US retailers will not list a children's product without a valid CPC and the supporting lab reports.
Key takeaways
- A children's product is one designed or intended primarily for children 12 or under. Age grading, packaging, advertising and how consumers see it all count.
- The CPC is self-certification by the importer or domestic manufacturer. It is not a CPSC approval, registration or licence.
- Children's products need third-party testing at a CPSC-accepted lab for each applicable rule. A lab report alone is not a CPC.
- Since 8 July 2026, Part 1110 requires updated certificate content (unique product ID, fuller contacts, attestation). Importers must eFile; domestic makers do not eFile but must meet the new content rules.
- Furnish the CPC to distributors and retailers (hard copy or electronic). Keep supporting records for five years and retest at least yearly in most cases.
- Cosmetics are mainly FDA territory, but a play makeup kit, children's bath set or toy packed with cosmetics can still be a children's product under CPSIA and need a CPC for the CPSC rules that apply.
If you sell anything in the United States that a child of twelve or under is meant to use - a bath gift set, play makeup, a novelty soap shaped like a cartoon, a wash mitt sold in the toy aisle - somebody will ask you for a Children's Product Certificate. Amazon asks before listing. Customs asks at the border. Retail buyers ask during onboarding. The document looks simple. Getting it wrong is how containers sit on the dock and listings get pulled.
This guide covers what the CPSC actually wants on a CPC: what counts as a children's product, which rules usually apply, why the lab must be CPSC-accepted, what the certificate must say under the July 2026 Part 1110 rules, who is allowed to issue it, how it differs from a General Certificate of Conformity, and where cosmetics fit. For the wider statute, start with our CPSIA overview. For the marketing trap of calling something "CPSC certified", see what CPSC certified really means.
What a CPC is (and is not)
A Children's Product Certificate is a written statement by the finished-product certifier - the importer of a foreign-made children's product, or the domestic manufacturer of a US-made one - that the product complies with every applicable CPSC children's product safety rule. The statement must rest on passing tests from a third-party laboratory the CPSC has accepted for each of those rules. Section 14 of the Consumer Product Safety Act, as carried in 16 CFR Part 1110, is the legal home of that duty.
Three things a CPC is not:
- Not a CPSC approval. The Commission does not test your product, endorse it or put a stamp on the box. You certify. The CPSC enforces.
- Not the lab report. A passing test report supports the certificate. It does not replace it. CPSC guidance is explicit that reports alone do not satisfy Part 1110.
- Not a licence you apply for. You do not file a CPC with the CPSC for approval. Importers now eFile certificate data at entry; that is a customs data filing, not an approval.
Plain English
Think of the CPC as your company's signed statement: "We imported (or made) this children's product, these are the rules it had to meet, this accepted lab tested production samples, and here is who holds the records."
What counts as a children's product
Under the CPSIA, a children's product is a consumer product designed or intended primarily for children 12 years of age or younger. "Primarily" is judged on four factors the CPSC uses in its Age Determination Guidelines:
- the manufacturer's statement of intended use, including labelling and instructions
- how the product is represented in packaging, display, promotion or advertising
- whether consumers commonly recognise it as meant for that age group
- the CPSC's own age-determination guidance
A product does not escape the definition because adults also buy it. A bath bomb shaped like a cartoon character and sold next to toys is a children's product however many grown-ups put it in their own tub. Borderline cases ("family" gift sets, unisex novelty soaps, makeup sold without an age grade) should be walked through those four factors in writing, not assumed. Our CPSIA guide goes deeper on the definition; the certificate work starts once you have decided.
Which rules typically sit behind a CPC
The CPC certifies compliance with each children's product safety rule that applies. Which rules apply depends on the product. For most small-brand children's bath, beauty and novelty items the usual set looks like this:
| Rule / issue | Why it shows up | Typical trigger |
|---|---|---|
| Lead content in children's products | Total lead limits for substrate | Almost every children's article |
| Lead in paint and surface coatings | 16 CFR Part 1303 | Painted toys, printed packaging decorations, coated parts |
| Phthalates | Specified phthalates in toys and child care articles | Soft plastics, vinyl, scented toys |
| Small parts | 16 CFR Part 1501 for under-threes | Products intended for under 3; choking hazard |
| Toy safety (ASTM F963) | Incorporated via 16 CFR Part 1250 | Anything that is a toy, including a duck in a bath set |
| Tracking label | 15 U.S.C. § 2063(a)(5) | Children's products and packaging, to the extent practicable |
Product-specific standards (cribs, pacifiers, children's sleepwear, durable infant products) sit on top when relevant. The certifier must list every applicable rule. A CPC that cites only lead when the product is also a toy is incomplete, and marketplace reviewers catch that quickly.
Children's cosmetics: FDA and CPSC at the same time
Cosmetic ingredient safety and MoCRA product listing are FDA work. Cosmetics as such sit outside the CPSA definition of "consumer product". That does not give children's bath and play-beauty ranges a free pass.
A play makeup kit, a children's bath set that includes a rubber duck, or a novelty soap marketed to under-twelves is still a consumer product for children. The CPSC rules that apply to that article - lead, phthalates, small parts, ASTM F963 where there is a toy, tracking labels, and in some cases special packaging under the Poison Prevention Packaging Act - still need third-party testing and a CPC. Packaging of children's cosmetics can also bring lead limits into play. In practice many kids' sets need both: FDA cosmetic compliance for the formula and label, and a CPSC certificate for the children's-product rules. For the EU/UK safety-report side of under-threes, see CPSR for baby and children's cosmetics.
Worked distinction
Adult lipstick sold as adult makeup: FDA cosmetic rules, no CPC. The same lipstick packed inside a plastic toy vanity marketed for ages 5-8: the vanity is a children's product (and likely a toy), so ASTM F963, lead, phthalates and a CPC arrive alongside the FDA duties on the lipstick.
Third-party testing at a CPSC-accepted laboratory
This is the feature that separates a CPC from a GCC. Children's product certification must rest on passing results from a third-party conformity assessment body the CPSC has accepted for the specific rules being certified. Check the CPSC accepted-laboratory search before you book. Acceptance is per rule, not a blanket badge.
What does not qualify:
- your own first-party lab results
- a supplier certificate from a lab that is not CPSC-accepted for that rule
- a European or UK test report written against a different standard, however reputable the lab
- a prototype sample that does not represent the production product
Testing must be on samples representative of the finished product as sold. Under 16 CFR Part 1107, most children's products need periodic retesting at least once a year. A production testing plan can stretch that to two years; an ISO/IEC 17025 quality system can stretch it to three. Any material change - new material, new component supplier, new colourant, changed process - triggers retesting for the rules the change could affect, and a fresh certificate. Keep the supporting records for five years.
Registered small-batch manufacturers have limited relief for certain rules: where third-party testing is not required, the CPC cites the CPSC registration number in the laboratory element instead. That is a narrow carve-out, not a general exemption from certification.
What the certificate must contain (July 2026 rules)
On 8 July 2026 the rewritten 16 CFR Part 1110 took effect for domestically manufactured products and for most imports (Foreign Trade Zone entries follow on 8 January 2027). The CPSC's longstanding "seven elements" guidance is still the right mental model; the regulation now tightens identification, contact fields and attestation. In practice a finished-product CPC needs:
| Element | What to put |
|---|---|
| 1. Product identification | At least one unique identifier (GTIN, model, SKU, UPC, serial, registered or alternate ID) plus a description that matches the finished product and no others |
| 2. Rules cited | Each applicable children's product safety rule, listed separately. If an exemption or determination means a rule was not tested, still cite the rule and note the exemption |
| 3. Certifier | Name, full mailing address, email and telephone of the importer or domestic manufacturer issuing the certificate |
| 4. Records contact | Name (or always-staffed position), full address, email and telephone of the person who holds the test records |
| 5. Date and place of manufacture | At least month and year, and city/region, state if any, and country of finished-product assembly (street address if the maker has more than one site in that city) |
| 6. Date and place of testing | When and where each test or test report was produced, with the lab's full contact details |
| 7. Attestation | The Part 1110 attestation that the products comply and that the information is true; false statements are a federal crime |
The CPC and supporting test reports must be in English. No official template is required so long as the required content is present and accurate. CPSC publishes illustrative examples for a toy, clothing, a bassinet and a blanket (including how to cite an exemption).
Who issues the CPC
For products manufactured outside the United States, the importer is the finished-product certifier. For products manufactured in the United States, the domestic manufacturer is (a private labeler may certify instead unless the manufacturer does). CPSC guidance is blunt on two points overseas brands get wrong:
- You cannot simply pass along a foreign manufacturer's CPC. The importer issues its own. You may rely on the factory's test results only with due care under 16 CFR Part 1109.
- The certifier does not have to be physically located in the United States, and the certificate need not list a US address. What matters is that the firm named as certifier is the one legally responsible - typically the importer of record on the customs entry.
For a UK or EU brand selling into the US, that usually means either importing through its own entity or appointing a US partner who is the importer of record and will issue the CPC. Getting the name wrong - factory as certifier, brand as certifier when a different company is the importer of record - is still the single most common defect we see on CPC packs from overseas makers.
Electronic copies, who must receive it, and eFiling
For domestically manufactured products, the CPC must accompany each product or shipment, be furnished to each distributor or retailer, and be available to the CPSC on request. A hard copy or an electronic copy (for example a dedicated URL referenced on the invoice) both work.
For imports, since 8 July 2026 certificate data must be eFiled into CBP's ACE system at entry, either as a Full PGA Message Set or by referencing a record in CPSC's Product Registry. eFiling does not apply to domestically manufactured goods, but those goods still need the updated certificate content. There is no de minimis carve-out for eFiling. Agree with your customs broker, before the first shipment, who keys the data and which Product ID type you will use.
CPC versus GCC
| Children's Product Certificate (CPC) | General Certificate of Conformity (GCC) | |
|---|---|---|
| Applies to | Products intended primarily for children 12 and under | Non-children's (general-use) products subject to a CPSC rule |
| Testing basis | Third-party testing at a CPSC-accepted lab (mandatory, subject to narrow exemptions) | Testing or a reasonable testing programme; first-party testing permitted |
| Issued by | Importer or domestic manufacturer (or private labeler) | Importer or domestic manufacturer (or private labeler) |
| Lab on the certificate | CPSC-accepted lab required (or small-batch registration / exemption citation) | Third-party lab details only if you chose to use one; otherwise may be N/A |
| Typical products | Toys, children's bath sets, play cosmetics, children's clothing | Adult apparel flammability, certain household products, PPPA special packaging on adult products |
Full detail on the GCC side sits on the CPSC GCC page. Do not put a children's product on a GCC and hope nobody notices.
Tracking labels sit beside the CPC
Separately from the certificate, children's products must carry a permanent tracking label on the product and its packaging to the extent practicable: manufacturer or private labeler name, location and date of production, and cohort information such as a batch or run number, so a recall can find the right units. Amazon routinely asks for photos of the tracking label during children's-product onboarding. A perfect CPC with no tracking label is still non-compliant.
A worked example: children's bath gift set
A UK maker wants to sell a children's bath set into the US: three small bath bombs, a rubber duck and a fabric wash mitt, in a printed box aimed at ages 3-8.
- The bath bombs are cosmetics. Formula, labelling and MoCRA listing are FDA work.
- The set as a whole is a children's product under CPSIA because it is marketed to that age group.
- The duck is a toy. It needs ASTM F963 testing, lead content, lead in paint, and phthalates. Small-parts testing is not triggered for ages 3-8, but the age grade must be justified.
- The wash mitt is a children's textile: lead, and lead in paint if it has printed decoration.
- The box, duck and mitt need tracking labels.
- The US importer of record - not the UK factory - issues one CPC covering every applicable rule, supported by reports from a CPSC-accepted laboratory, and eFiles the certificate data at entry.
Get that pack assembled before the first container ships. It is cheaper than a hold at the border and a suspended Amazon listing.
Importing and marketplace checks
CBP and the CPSC target children's products. Shipments can be held while the CPC and test reports are requested. A shipment without a valid certificate can be refused entry. The importer named on the CPC should match the importer on the entry documents. Treat the certificate as a shipping document, not only a marketplace document.
Amazon and other US retailers typically want the CPC, the supporting test reports, and images showing the tracking label and any required warnings before they will list many children's products. Common rejection reasons: missing Part 1110 content, a lab not accepted for the cited rule, or a certificate issued by the foreign factory instead of the importer of record. Our notes on marketplace compliance documents and Amazon, Etsy and Shopify cosmetic rules cover the wider document pack sellers get asked for.
Common mistakes
- Wrong certifier. Factory named when a different company is the importer of record.
- Unaccepted laboratory. Lab missing from the CPSC list for that specific rule.
- Missing rules. Lead only, when the product is also a toy subject to ASTM F963 and phthalates.
- Missing elements. No unique ID, no attestation, no records email, incomplete manufacture location.
- Prototype testing. Report based on a hand sample that does not match production.
- No retest after a change. New paint supplier, new plastic, new scent component - no new testing.
- No tracking label. Certificate present, permanent label absent.
- Assuming FDA covers it. Children's cosmetics still need CPSIA compliance for the children's-product rules that apply.
- Ignoring eFiling. Paper CPC in the carton but no ACE filing on an import entry after 8 July 2026.
Need a CPC that marketplaces and customs will accept?
Send us the formula, packaging and intended age grade. We map the applicable CPSC rules, coordinate CPSC-accepted lab testing and prepare the Children's Product Certificate for your US importer or domestic manufacturer.
Related reading
- CPSIA explained: which products count as children's products
- What "CPSC certified" really means (and why there is no such thing)
- CPSR for baby and children's cosmetics under three
- Cosmetic marketplace compliance documents explained
- US vs UK and EU cosmetics rules, side by side
- MoCRA product listing and facility registration
- MoCRA software vs a compliance consultant
- Amazon, Etsy and Shopify cosmetic product rules
- All regulatory compliance articles
Myths we hear
- The CPSC certified my product. The CPSC never certifies products. You (or your US importer) issue the CPC based on accepted-lab testing. Saying 'CPSC approved' is both wrong and a risky marketing claim.
- Any ISO lab can do the testing. The lab must appear on the CPSC's accepted list for each specific children's product safety rule you cite. An unaccepted lab, or a lab accepted only for a different rule, does not support a CPC.
- A CPC is only for toys. It covers any consumer product designed or intended primarily for children 12 or under that is subject to a CPSC children's product safety rule: clothing, bath sets, play cosmetics, sleepwear, durable infant products and more.
- My Chinese factory's CPC covers me as the importer. CPSC guidance is clear: the importer issues its own certificate. You may rely on the factory's test results only if you exercise due care under 16 CFR Part 1109. You cannot simply pass the factory's CPC along.
- FDA cosmetic compliance means I don't need a CPC. Ingredient safety and MoCRA listing sit with the FDA. Lead, phthalates, small parts, toy standards and tracking labels sit with the CPSC when the item is also a children's product. Many kids' bath and makeup sets need both.
What to do this week
- Decide, product by product, whether it is a children's product under the four-factor age determination (intended use, packaging and ads, consumer recognition, CPSC Age Determination Guidelines).
- Map every applicable CPSC children's product safety rule: lead content, lead in paint, phthalates, small parts, ASTM F963 where it is a toy, tracking labels, and any product-specific standard.
- Book production samples with a lab that is CPSC-accepted for each of those rules, and keep the passing reports.
- Issue your own CPC with the Part 1110 content (unique ID, rules, certifier, records contact, manufacture and test dates/places, lab details, attestation), in English.
- Put a permanent tracking label on the product and packaging to the extent practicable.
- If you import, set up eFiling (Full PGA Message Set or Product Registry + Reference set) with your customs broker. Plan annual retesting and retest after any material change.
Frequently asked questions
What is a Children's Product Certificate?
It is a written certificate in which the importer (for foreign-made goods) or the domestic manufacturer (for US-made goods) states that a children's product complies with every applicable CPSC children's product safety rule, based on testing by a CPSC-accepted third-party laboratory. The CPSC does not issue, approve or register it.
Which products need a CPC?
Any consumer product designed or intended primarily for children 12 years of age or younger that is subject to a CPSC children's product safety rule. Toys, children's clothing, children's bath gift sets and play cosmetics are everyday examples. General-use products that are regulated by the CPSC use a General Certificate of Conformity instead.
Who issues the CPC for a product made overseas?
The importer of record. A foreign factory's certificate cannot simply be passed along. The certifier does not have to be located in the United States, but the name on the CPC must be the firm that is legally importing the goods. For a UK or EU brand selling into the US, that usually means its own importing entity or a US partner who is the importer of record.
What must a CPC contain under the July 2026 rules?
Under rewritten 16 CFR Part 1110: a unique product identifier plus description; each applicable children's product safety rule; the certifier's full contact details including email; the records custodian's contact details; date and place of manufacture; date and place of testing with lab details; and the certifier's attestation. The older CPSC 'seven elements' guidance is the same idea, now with tighter identification and attestation requirements. The CPC and supporting reports must be in English.
Can I use my own lab or a European test report?
No for children's products. Testing must be done by a third-party conformity assessment body that the CPSC has accepted for each specific rule you cite. Your own first-party tests, a supplier report from an unaccepted lab, or a CE/UKCA report against a different standard do not support a CPC. Search the CPSC accepted-laboratory list before you book.
What is the difference between a CPC and a GCC?
A CPC is for children's products and must rest on CPSC-accepted third-party testing. A General Certificate of Conformity (GCC) is for non-children's (general-use) products that are still subject to a CPSC rule; it may rest on the certifier's own testing or a reasonable testing programme. Both now follow Part 1110 content rules.
Do children's cosmetics need a CPC?
Often yes for the CPSC rules that apply. Cosmetic ingredients and MoCRA listing are FDA matters. But a play makeup kit, a children's bath set with a toy, or packaging of children's cosmetics can still be a children's product under CPSIA, which brings lead, phthalates, small parts and, where the item is a toy, ASTM F963 into play. Those need a CPC.
Do I have to eFile my CPC?
If you import a regulated consumer product into the US, yes, as of 8 July 2026 (Foreign Trade Zone entries follow on 8 January 2027). You eFile certificate data in CBP's ACE system using a Full PGA Message Set or a Product Registry reference. Domestically manufactured products are not eFiled, but they must still meet the updated certificate content and be furnished to distributors and retailers.
Official sources and legislation
- CPSC: Children's Product Certificate (CPC)
- CPSC: General Certificate of Conformity (GCC)
- CPSC: Update on Certificates of Compliance and eFiling
- CPSC: Consumer Product Safety Improvement Act (CPSIA)
- CPSC accepted laboratory search
- CPSC FAQ: Initial Certification Testing
- CPSC FAQ: eFiling
- 16 CFR Part 1110 Certificates of Compliance (eCFR)
- 16 CFR Part 1107 Testing and Certification (eCFR)
- Federal Register: Certificates of Compliance (90 FR 1800, 8 Jan 2025; effective 8 Jul 2026)
- FDA: Cosmetics (agency overview)
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