Does the packaging of a children’s product need CPSC lab testing for the CPC?

What CPSC says

Packaging “is generally not intended for use by children, given that most packaging is discarded,” and “disposable packaging is not subject to third-party testing and certification requirements” CPSC total lead FAQ. A lab result for the bag or the box is not something your CPC needs.

The exception, in the same answer: “if the packaging is intended to be reused or used in conjunction with the children’s product, such as a heavy gauge reusable bag to hold blocks, the bag becomes a component or part of the product” and is subject to the children’s product rules that apply CPSC total lead FAQ, starting with the 100 ppm lead content limit for accessible parts 15 U.S.C. 1278a.

What still applies to the packaging

• The tracking label: its information goes on the product and its packaging, to the extent practicable 15 U.S.C. 2063(a)(5). CPSC says both are marked in most instances, that an adhesive label on disposable packaging may be enough there, and that packaging needs no separate mark if the product’s label is visible through it CPSC tracking label FAQ.
• State law: CPSC notes that many states have their own laws on toxics in packaging CPSC total lead FAQ. State laws based on a model, passed in 19 states as of 2021, ban intentionally added lead, cadmium, mercury and hexavalent chromium, and cap the four combined at 100 ppm Toxics in Packaging Clearinghouse; the packaging maker or supplier furnishes a certificate of compliance on request Model legislation, sec. 7. That certificate is separate from your CPC.