Choosing a CPSC-accepted lab for third-party testing

A children's product that is subject to a children's product safety rule must be tested by an accredited third-party lab before you can issue its Children's Product Certificate (CPC) and import or distribute it (15 U.S.C. 2063(a)(2)). The lab has to be accredited to test for compliance with each of those rules, so check that its accreditation covers every rule your product is subject to. One lab may not cover them all.

Examples of rules a lab's scope may need to cover:

• Toys — the toy safety standard, 16 CFR part 1250, which makes ASTM F963 mandatory
• Paint and surface coatings — the lead paint ban, 16 CFR part 1303
• Toys and child care articles — the phthalates prohibition, 16 CFR part 1307
• Clothing textiles — flammability, 16 CFR part 1610
• Children's sleepwear — flammability, 16 CFR parts 1615 and 1616
• Cribs — 16 CFR parts 1219 and 1220

This is not a complete list. Which rules apply depends on the product.

When to test again (16 CFR part 1107):

1. Initial certification — before you first certify the product
2. Material change — a change in design, manufacturing process, or component sourcing that could affect compliance means new third-party testing and a new CPC (16 CFR 1107.23(a))
3. Periodic testing — third-party testing at least once a year; at least once every two years if you run a production testing plan; or at least once every three years if you also test with an ISO/IEC 17025-accredited lab (16 CFR 1107.21(b)–(d))

WARNING: A lab owned, managed, or controlled by the manufacturer or private labeler is not a third-party lab unless CPSC has accredited it, by order, as a "firewalled" lab. CPSC does that only after finding it gives equal or greater consumer safety protection and has procedures that protect test results from undue influence (15 U.S.C. 2063(f)(2)(D)). Don't treat a factory's own test report as third-party testing unless the lab holds that accreditation.