[Home](/)/[Resources](/resources)/CPSIA Children's Products USProduct safety guide # CPSIA for Children's Electronics: Lead Limits, Phthalates, and the CPC The Consumer Product Safety Improvement Act imposes strict lead content limits, phthalate restrictions, mandatory third-party testing at a CPSC-accredited lab, and a Children's Product Certificate requirement on any electronics product primarily intended for children under 12 — before a single unit enters US commerce. Penalties for non-compliance reach $15 million per related series of violations and CPSC actively enforces at the border and online. Copy Link[Share on WhatsApp](https://wa.me/?text=https%3A%2F%2Fkrono-labs.com%2Fguides%2Fus-cpsia-children-products) At a glance Law CPSIA (2008, amended) Lead limit 100 ppm (substrate) Phthalates 0.1% per accessible part Certificate Children's Product Certificate (CPC) ## CPSIA requirements for electronics ### What is a children's product under CPSIA CPSIA defines a children's product as a consumer product designed or intended primarily for children 12 years of age or younger. 'Primarily intended for' is determined by a four-factor test: statements by the manufacturer, the product's advertising and marketing, whether the product is commonly recognised as intended for children, and the Age Determination Guidelines published by CPSC. Electronics targeting children — educational tablets, learning toys with electronic components, kid-targeted smart speakers, children's GPS trackers — are typically children's products and subject to the full CPSIA framework. ### Lead content limits CPSIA sets a 100 ppm total lead limit for children's products (all component parts). Substrate materials must not exceed 100 ppm lead content. Paints and surface coatings are further restricted to 90 ppm lead by weight (ASTM F963). Electronic components — PCBs, solder, connectors, battery contacts — must comply. Lead-free solder (Sn/Ag/Cu) is standard practice in most electronics but some legacy components and certain connector types may still contain lead above limits. ### Phthalate restrictions Eight phthalates are prohibited in children's toys and childcare articles at concentrations greater than 0.1% by weight in any accessible component. For electronics, phthalates in PVC-insulated cables, plastic housings, and soft-touch grip materials are the primary exposure risk. A 'childcare article' is defined as a consumer product designed to facilitate sleep, feeding, sucking, or teething of children under 3 — a broader category than 'toy' that can capture some soft electronics accessories. ### Third-party testing and Children's Product Certificate All children's products must be tested by a CPSC-accredited third-party laboratory before being imported or distributed in US commerce. Based on those test results, manufacturers and importers must issue a Children's Product Certificate (CPC) — the US equivalent of a CE declaration of conformity for children's products. The CPC must identify the product, the applicable rules and standards it complies with, the testing results, and the contact information of the responsible party and the accredited test lab. ## Compliance process 01 Determine whether your product is a children's product under CPSIA using the CPSC's four-factor test and Age Determination Guidelines — if the marketing targets children under 12, assume it is in scope. 02 Identify all applicable rules and standards for your product type: lead content limits (16 CFR Part 1303), phthalate restrictions (16 CFR Part 1307), ASTM F963 for toys (if applicable), and any product-specific mandatory standards (e.g., for powered ride-on toys, plush toys with electronics, or battery-operated devices). 03 Conduct lead and phthalate testing at a CPSC-accepted, CPSC-accredited third-party laboratory — the CPSC maintains a list of accredited laboratories on its website; testing must follow the specific methods required by each applicable standard. 04 Obtain test reports from the accredited lab and issue a Children's Product Certificate (CPC) based on those results — the CPC must be in English, available to CPSC and customers on request, and kept for 5 years. 05 Apply a tracking label to each unit of the children's product, permanently attached in a location children can access: the label must identify the manufacturer, production date, and place of manufacture — this enables targeted recalls without requiring retailers to contact all customers. 06 Review packaging and marketing materials to confirm they do not create implied claims of suitability for ages outside your tested range — age grading must match the product's CPSIA testing scope. 07 Establish a written Children's Product testing programme (if you manufacture or import more than $1M of children's products annually, a formal programme is expected): document your test frequency, sample selection, and how you handle changes to products or manufacturing that require re-testing. ## Frequently asked questions ### Does CPSIA apply to electronics sold online from outside the US? Yes — CPSIA applies to products imported into the United States and to products distributed in US commerce. Foreign manufacturers selling direct to US consumers through their website or through online marketplaces are legally required to comply and to issue CPCs. CBP enforces CPSIA at the border and CPSC conducts market surveillance on products offered for sale online. ### What is the penalty for selling a non-compliant children's product? Civil penalties under CPSIA can reach up to $100,000 per violation and up to $15 million for a related series of violations. The CPSC publishes enforcement actions and has assessed multi-million dollar penalties against companies selling non-compliant children's products. Criminal penalties are also available for knowing violations. Beyond fines, CPSC can order a mandatory recall, which creates both direct recall costs and significant reputational damage. ### How often does a children's product need to be re-tested? CPSIA requires testing for each model of children's product initially before it is sold. Re-testing is required when there is a material change in the product's design, the materials or component suppliers, the manufacturing process, or the location of manufacture. CPSC guidance recommends periodic testing (typically annually) even without product changes to verify ongoing compliance. Some mandatory standards have their own re-testing intervals. ### Does CPSIA apply to the packaging of children's products? CPSIA lead and phthalate limits apply to the children's product itself, including all accessible component parts. Packaging is not typically a children's product itself — but if packaging materials could become accessible to children during use (e.g., a toy box that a child interacts with), the same limits apply. The Consumer Product Safety Act separately requires that packaging for certain products meet child-resistant requirements under PPPA (Poison Prevention Packaging Act). **Disclaimer:** Educational resource only. CPSIA requirements vary by product category and age group. Consult a CPSC-accredited test laboratory or qualified US product safety specialist before placing children's products on the US market. 🇺🇸 US roadmap for toys Every standard, document, and test that applies — free, no account required. See your free roadmap[ Want an expert to take toys through 🇺🇸 US compliance for you? One consultant from Krono's compliance team takes your product from requirements to legal sale, with a fixed quote before any work starts. 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