Every children's product sold in the United States is covered by the Consumer Product Safety Improvement Act, and a wooden toy made in China is no exception. The act places the legal duty on the company that imports the goods, not on the factory, which is why US buyers are asked for documents their Chinese supplier may never mention.
This is the checklist we work through with US importers before the container leaves Yunhe.
1. The importer is the manufacturer of record
Under US rules the importer is treated as the manufacturer of the finished product. That means the test reports, the certificate and the tracking label all have to be in the importer's name, and it is the importer who answers to the Consumer Product Safety Commission if something is wrong. A report issued to our factory, or to another buyer, does not transfer that duty.
2. What actually has to be tested
For a wooden toy the test plan normally covers four areas:
- ASTM F963 - the toy safety standard, which is mandatory for toys in the US. Physical and mechanical hazards, flammability and heavy metals in surface coatings are all part of it.
- Total lead in accessible parts, and lead in surface coatings at the much lower paint limit.
- Phthalates in accessible plastic and vinyl parts - relevant if your wooden toy has a plastic handle, wheel or sound module.
- Small parts for anything intended for children under three, plus the warning label rules that go with the age grade.
Tests are run against the age grade printed on the packaging, so the age you choose decides the cost and scope of the plan. Our wooden toy safety standards page lists the standards item by item, and /knowledges/181.html explains how age grading changes the test list.
3. The Children's Product Certificate
The CPC is a one to two page document, based on testing carried out at a CPSC-accepted third-party laboratory. It names the product, the manufacturer or importer, the date and place of manufacture, the date and place of testing, the standards tested and the contact details of the person who keeps the test records. It is issued by the importer, not by the lab and not by the factory.
Practically, we prepare the sample plan, send the samples, and hand you the laboratory report; you or your customs broker then issue the CPC from that report. Some buyers ask us to draft it and they sign it, which also works.
4. Tracking labels
Children's products need a permanent tracking label on the product or its packaging showing the manufacturer or importer, the production location and the production date or batch. On wooden toys the label usually goes on the packaging and, where the surface allows, a batch code is stamped or printed on the item as well.
5. The five mistakes that cost the most time
- Using a generic test report that describes "wooden toy" rather than the exact item, colour and components.
- Testing a sample that was pulled from a different production run than the goods being shipped.
- Choosing the age grade after testing instead of before design.
- Forgetting components - a plastic knob or a textile strap needs its own coverage.
- Starting production before the specification is frozen, so the tested sample and the shipped goods differ.
6. What we hand over
For a US order we normally provide the bill of materials with surface area notes, samples for third-party testing, the factory's own EN71 and ASTM history, and the packaging artwork with the age warning and tracking label position marked. If your buyer or insurer asks for social compliance as well, we can share the BSCI audit and the FSC chain of custody certificate.
If you are running the numbers for a first US order, the most useful next step is a specification and a target age grade - send both through our contact form and we will come back with a test plan and a quotation. Stock items with no development work start from our wholesale wooden toys range, and custom projects run through OEM wooden toys.
Related reading: the European half of the same checklist is on the EN71 test report guide, and the buyer-side checks that apply in both markets are collected in choosing safe wooden toys.
The documents we currently issue against these requirements, with their dates, are listed in the EU and US toy safety compliance update.
The same document, compared market by market against the EU, UK, Canadian and Australian requirements, is in wooden toy import requirements by market.
Under private label, the name that has to appear on that certificate is yours rather than ours.
The requirements this certificate rests on are set out in CPSIA for wooden toys and ASTM F963, and how they change the way an order is built in wooden toy manufacturing for Amazon sellers.