Do children’s leather shoes need CPSC lead testing? Which parts are exempt?
Children’s shoes need a Children’s Product Certificate based on tests by a CPSC-accepted lab. Tanned and dyed leather is exempt from lead testing, so the tests usually come down to the sole, metal parts such as eyelets and buckles, and any finish or print that forms a film. Phthalate, flammability and small parts tests do not apply.
The rules that apply
- Lead: no more than 100 ppm in any accessible part 15 U.S.C. 1278a. Paint and film-forming finishes meet the 90 ppm lead paint limit 16 CFR part 1303.
- A permanent tracking label on one shoe of the pair CPSC tracking label policy and on the box 15 U.S.C. 2063(a)(5).
- Tests and certificate come before import 15 U.S.C. 2063(a)(2). The importer certifies 16 CFR 1110.7 and eFiles the data at entry 16 CFR 1110.13(a)(1).
- Not for shoes: phthalates, as shoes are neither toys nor child care articles CPSC phthalates FAQ; clothing flammability 16 CFR 1610.1(c)(3); small parts 16 CFR 1501.3(d).
Component by component
| Component | Lead test? | Why |
|---|---|---|
| Leather upper, lining, insole (tanned and dyed) | No | CPSC determination 16 CFR 1500.91(d)(8), dyed leather included 74 FR 43037; the CPC names it 16 CFR 1110.11(c) |
| Pigmented, patent or metallic finish, painted edges, prints | Paint test if it scrapes off; otherwise total lead | The scrape test decides CPSC lead in paint FAQ |
| Rubber or TR sole | Yes, per compound or color | No exemption: the textile rule’s “rubber” is a fiber 16 CFR 1500.91(d)(7) |
| Eyelets, buckles, snaps | Yes, unless an exempt metal | Exempt: stainless steel UNS S13800–S66286 (not 303Pb), listed precious metals 16 CFR 1500.91(e); plating is no barrier 16 CFR 1500.87(b) |
| Thread, laces, elastic | No, if only dyed | Coated laces and lace tips are tested 16 CFR 1500.91(d)(7) |
| Glue, toe puff, counter, shank, insole board | No, if a child cannot reach them | Judged on the finished shoe 16 CFR 1500.87(b) |
Many styles, factory reports, short runs
Footwear models that were composite tested together count as one product for the certificate, as long as no material change separates them 90 FR 1815; a sole color or finish outside those tests needs its own tests and, if materially different, its own certificate Registry FAQ v1.4.
A factory’s report counts only if a CPSC-accepted lab ran that test on an identical, traceable material and you get the records 16 CFR 1109.5. A European soluble-lead test does not replace total lead CPSC total lead FAQ.
Short runs generally need no periodic tests, but an importer with little control over the factory likely needs to test each new shipment CPSC periodic testing FAQ. Leather-upper shoes enter under heading 6403 HTSUS 6403; one 6403 code is on CPSC’s eFiling list CPSC HTS list, Oct. 2026 (see our HTS list), yet imported children’s shoes are eFiled anyway.
You can order the tests and write the certificate yourself. If you would rather not, send us your factory’s materials list and any lab reports: we tell you which tests are still needed, check each report against its rule and the lab’s CPSC acceptance, then write the CPC, the Registry import file and the broker sheet. $79 per certificate, 2 U.S. business days, or the Catalog Plan for up to 10 certificates a month. We do not test products.
Last reviewed: October 15, 2026 · First published: October 15, 2026 · Not legal advice.
Sources read October 15, 2026
- 15 U.S.C. 1278a — Lead limits in children’s products
- 16 CFR part 1303 — Lead in paint and similar surface coatings
- CPSC statement of policy on tracking labels, section 103(a) of the CPSIA (2009): one shoe of the pair
- 15 U.S.C. 2063 — Certificates, third-party testing, tracking labels
- 16 CFR 1110.7 — Who must certify
- 16 CFR 1110.13 — Certificate availability and eFiling
- CPSC, FAQ: Phthalates (children’s shoes and socks)
- 16 CFR 1610.1(c) — Items outside the clothing flammability standard
- 16 CFR 1501.3 — Small parts rule exemptions
- 16 CFR 1500.91(d)(8) — Lead content determination for leather and other animal- or plant-derived materials
- CPSC final rule, lead content determinations, 74 FR 43031 (Aug. 26, 2009), part D.13(c): leather (pp. 43036–37)
- 16 CFR 1110.11 — Certificate content
- CPSC, FAQ: Lead in Paint (scraping test)
- 16 CFR 1500.91(d)(7) — Lead content determination for textiles
- 16 CFR 1500.91(e) — Lead content determination for stainless steel and precious metals
- 16 CFR 1500.87(b) — Lead: inaccessible component parts (plating is no barrier)
- CPSC final rule, Certificates of Compliance, 90 FR 1800 (Jan. 8, 2025)
- CPSC, Product Registry FAQ v1.4 (updated Apr. 28, 2026)
- 16 CFR 1109.5 — Relying on another party’s tests or certificates (due care, documentation)
- CPSC, FAQ: Total Lead Content (relying on suppliers; European soluble-lead tests)
- CPSC, FAQ: Periodic Testing (short production runs; importers)
- USITC, Harmonized Tariff Schedule, heading 6403 (footwear with leather uppers)
- CPSC, Guidance and HTS List for eFiling, October 2026 (Excel, posted Sept. 30, 2026)