CPSIA Children's Product Certificate (CPC)

The Consumer Product Safety Improvement Act of 2008 fundamentally restructured how children's product safety is enforced in the United States. Prior to CPSIA, manufacturers could largely self-certify compliance with CPSC safety rules. After CPSIA, children's products — defined as consumer products primarily intended for children 12 years of age and younger — must be tested by a CPSC-accepted third-party laboratory before they may be imported or sold, and the results must be summarised in a Children's Product Certificate (CPC) that accompanies each product through the supply chain.

The CPC must list every applicable CPSC children's product safety rule the product has been tested against and certified to comply with. For a typical toy, this list may include: Section 101 of CPSIA (lead in substrates), Section 108 (phthalates in children's toys and child care articles), ASTM F963 (Standard Consumer Safety Specification for Toy Safety), and any additional category-specific standards. For children's clothing, it includes CPSC flammability standards (16 CFR Part 1615/1616) and draw-cord regulations. The CPC must also identify the CPSC-accepted laboratory that performed each test and provide a URL or other contact information through which anyone in the supply chain can obtain copies of the supporting test reports.

A second CPSIA requirement that catches importers off guard is the tracking label obligation. Every children's product and its packaging must bear a permanent label — not a hang tag that can be removed — identifying the manufacturer, the location and date of manufacture, and a cohort identifier (such as a lot number) that allows the product to be traced back to its production batch. This label must be designed to survive the product's expected use life. A product shipped with only a removable hang tag satisfies neither the CPC nor the tracking label requirement. Sustalium generates the CPC in the standard format expected by US retailers and CPSC examiners, manages test report version control across model updates, and provides a tracking label specification template that factory production teams can implement correctly.