CPSIA checklist, row by row

Every CPSIA requirement on a children's product's checklist: what the rule asks and how to record it.

Every row of a product's CPSIA checklist, in the order the checklist shows them, with the regulation's full wording, who does the work, when it applies and each way to record it. The checklist itself keeps only the row's name, its citation and the buttons to record it.

INFO: The records listed under 16 CFR 1107.26 are what CPSC asks for, and they are yours to hold: §1107.2 defines "manufacturer" as whoever certifies under part 1110, and for anything made outside the US that is the importer. Keep those records five years. The tracking label is a marking on the product and its packaging, not a record.

Children's Product Certificate (16 CFR 1107.26(a)(1), for each product). A copy of the CPC for each product, with the product it covers clearly identifiable and distinguishable from your other products.

Whose work it is: Yours to issue. Once you have issued the certificate for this product and hold it on file, record that here.

How it is met:

  • You issued this certificate and hold it on file — Confirm you have issued the Children's Product Certificate for this product and hold it on file.

Source: 16 CFR 1107.26(a)(1) — 76 FR 69541, Nov. 8, 2011, as amended at 77 FR 72219, Dec. 5, 2012; 86 FR 22866, Apr. 30, 2021 (eCFR title 16, issue date 2026-08-03). Read 2026-08-18.

Third-party certification test records (16 CFR 1107.26(a)(2), for each product). Records of each third-party certification test, kept separately for each manufacturing site. Testing must be done by a CPSC-accepted conformity assessment body.

How it is met:

  • A lab report on file — upload one of: Lab Report.

Source: 16 CFR 1107.26(a)(2) — 76 FR 69541, Nov. 8, 2011, as amended at 77 FR 72219, Dec. 5, 2012; 86 FR 22866, Apr. 30, 2021 (eCFR title 16, issue date 2026-08-03). Read 2026-08-18.

Periodic testing plan and results (16 CFR 1107.26(a)(3), for each product). A periodic test plan and results — or a production testing plan with results, or ISO/IEC 17025 lab testing — plus the periodic test results themselves. Periodic testing must be done by a third party.

How it is met:

  • Your recorded confirmation — Confirm you hold a periodic testing plan and its results for this product.

Source: 16 CFR 1107.26(a)(3) — 76 FR 69541, Nov. 8, 2011, as amended at 77 FR 72219, Dec. 5, 2012; 86 FR 22866, Apr. 30, 2021 (eCFR title 16, issue date 2026-08-03). Read 2026-08-18.

Representative sample records (16 CFR 1107.26(a)(4), for each product). How many representative samples you selected, the procedure used to select them, and the basis for inferring that production during the interval complies from those results.

How it is met:

  • Your recorded confirmation — Confirm you hold records of how representative samples were selected and why they support compliance.

Source: 16 CFR 1107.26(a)(4) — 76 FR 69541, Nov. 8, 2011, as amended at 77 FR 72219, Dec. 5, 2012; 86 FR 22866, Apr. 30, 2021 (eCFR title 16, issue date 2026-08-03). Read 2026-08-18.

Material change records (16 CFR 1107.26(a)(5), for each product). Descriptions of every material change in design, manufacturing process, or component sourcing, together with the certification tests run and the values obtained.

How it is met:

  • Your recorded confirmation — Confirm you hold records of material changes and the tests run after each.

Source: 16 CFR 1107.26(a)(5) — 76 FR 69541, Nov. 8, 2011, as amended at 77 FR 72219, Dec. 5, 2012; 86 FR 22866, Apr. 30, 2021 (eCFR title 16, issue date 2026-08-03). Read 2026-08-18.

Undue influence procedures and training (16 CFR 1107.26(a)(6), for each product). Your procedures to prevent undue influence on third-party testing, including training materials, records of everyone trained, and the attestations at §1107.24(b)(1).

How it is met:

  • Your recorded confirmation — Confirm you hold undue-influence procedures, training records, and the required attestations.

Source: 16 CFR 1107.26(a)(6) — 76 FR 69541, Nov. 8, 2011, as amended at 77 FR 72219, Dec. 5, 2012; 86 FR 22866, Apr. 30, 2021 (eCFR title 16, issue date 2026-08-03). Read 2026-08-18.

Tracking label on the product and its packaging (15 U.S.C. 2063(a)(5)(A), for each product). The manufacturer of a children's product must place permanent, distinguishing marks on the product and its packaging, to the extent practicable. The marks must enable the manufacturer to ascertain the location and date of production, cohort information (including the batch, run number, or other identifying characteristic) and any other information the manufacturer determines will help identify the specific source of the product; and enable the ultimate purchaser to ascertain the manufacturer or private labeler, the location and date of production, and cohort information. "Manufacturer" means any person who manufactures or imports a consumer product (15 U.S.C. 2052(a)(11)).

Whose work it is: This is a marking on the product and its packaging, not a document to file. Record it here once this product carries the marks.

How it is met:

  • Your recorded confirmation — Confirm this product and its packaging carry permanent, distinguishing marks giving the information described above, to the extent practicable.

Source: 15 U.S.C. 2063(a)(5)(A) — Pub. L. 110-314, §103(a), Aug. 14, 2008, as amended by Pub. L. 112-28, §6, Aug. 12, 2011 (15 U.S.C. 2063(a)(5); Consumer Product Safety Act §14(a)(5)). United States Code, 2023 Edition, U.S. Government Publishing Office (govinfo.gov). "Manufacturer" as defined at 15 U.S.C. 2052(a)(11), same edition.. Read 2026-10-10.

Not required, but worth holding

  • Product Specifications — Evidence for the material-change records at §1107.26(a)(5).
  • Quality Assurance Certificate — Supports the undue-influence procedures at §1107.26(a)(6).

INFO: This lists what the checklist records. It is not legal advice, and a row recorded in Aleph is not a finding that the product complies.