CPSIA for Wooden Toys
The CPSIA is the US law that sets the limits, not just the tests. For a wooden toy it decides the paint, the fittings, the certificate and the marking on the carton.
What the law actually restricts
The CPSIA amended US consumer product law and set numeric limits for children’s products, including toys. For a wooden toy the practical effect lands on three places: the wood and board, the coating, and any added part.
- The substrate. Wood and board are tested for total lead content, and so are fittings, screws, magnets and plastic components.
- The coating. Paint, ink and lacquer are restricted separately, because the exposure route is different. This is why a change of paint supplier matters even if the colour is identical.
- Phthalates. Restricted in toys and child care articles, which in practice means plastic components such as grips, wheels and packaging that forms part of the toy.
- Other rules. Separate federal rules cover small parts, sharp points and edges, rattles, and other specific hazards, and they apply alongside the CPSIA limits.
CPSIA duties that apply to a wooden toy
| Lead in substrate | 100 ppm limit for children’s products, applied to the wood, the board and any metal or plastic part. |
|---|---|
| Lead in surface coating | 100 ppm limit for the paint, ink, lacquer and any other coating on the toy. |
| Phthalates | Eight phthalates restricted to 0.1 percent in children’s toys and child care articles. |
| Children’s Product Certificate | Required for every shipment, based on testing at a CPSC-accepted third-party laboratory and naming the rule, the laboratory and the date and place of testing. |
| Tracking label | Permanent marking on the product or its packaging with the manufacturer or importer, the location, the production date and the batch or run. |
| Small parts | Toys intended for children under three must not contain small parts, and toys for three to six carry the small-parts warning where the rule applies. |
The Children’s Product Certificate
The CPC is the document a US customs officer or a marketplace compliance team asks for first. It is based on testing, and it has to be accurate.
- Who issues it. The importer or the domestic manufacturer — that is, the party placing the product on the US market.
- What it says. The product, the rule or ban it complies with, the importer or manufacturer details, the contact details of the person holding the test records, the date and place of manufacture, and the date and place of testing.
- What backs it. A test report from a laboratory accepted by the CPSC for that rule.
- When it changes. A change of material, coating, supplier or factory means the certificate has to be re-based on new testing.
Tracking labels: the requirement that catches people out
Every children’s product needs a permanent mark that allows it to be traced, and it has to survive the product’s normal life.
- What it contains — the manufacturer or importer, the location of production, the date of production and a batch, run or lot reference.
- Where it goes — on the product itself where it is practical, and otherwise on the packaging, with the mark visible and permanent.
- Why it exists — so that a recall can be limited to the units actually affected, which is the difference between a targeted notice and a whole-range withdrawal.
We print and apply the tracking information to your specification and keep the production record that the code points back to.
What we supply for a US order
- ASTM F963 test reports from a CPSC-accepted laboratory, per item and material combination.
- Material declarations for the wood, board, coatings and added parts, so the certificate can name what it is based on.
- Tracking-label artwork and printing to your specification.
- Batch records linking the shipped cartons to the production run, which is what a recall investigation asks for.
See ASTM F963 for the test specification and Wooden Toy Import Requirements for the market-by-market summary.
Related: ASTM F963 for wooden toys · CE marking for wooden toys · CPSIA and the CPC · OEM wooden toys · Private label wooden toys · Wooden toy manufacturer · Request a quotation
Frequently asked questions
What are the lead limits for a wooden toy in the US?
100 ppm for the substrate and 100 ppm for the surface coating. Both apply, so the wood or board and the paint are each tested separately.
Do wooden toys need phthalate testing?
The phthalate restriction applies to children’s toys and child care articles. On a wooden toy it covers plastic components such as grips, wheels, and any plastic part that forms part of the toy.
Who signs the Children’s Product Certificate?
The importer or the domestic manufacturer placing the product on the US market. We provide the test reports and material documentation that the certificate is based on.
What has to be on the tracking label?
The manufacturer or importer, the location of production, the production date and a batch or lot reference, permanently marked on the product or its packaging.
Does a change of paint need new testing?
Yes. The coating is restricted separately, so changing the paint or the ink means the existing report and certificate no longer describe the product being shipped.
Can you provide the test reports directly to our compliance team?
Yes. Reports per item can be sent to your compliance contact, and we can name a specific report reference in the shipping documents.
Send us your product list
Tell us the items, quantities and the market you sell in. We will come back with a quotation, the documentation we can supply, and the next step.
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