I make children’s products by hand in the U.S. Do I need a CPC and lab tests?
A CPC, yes, if a children’s product safety rule applies: the U.S. maker issues it before selling and produces it within 24 hours on request, with nothing to eFile. Lab tests, often: registered Small Batch Manufacturers can prove some rules, called Group B, without a CPSC-accepted lab, but never Group A rules such as lead in paint.
Who certifies, and when
For products made in the United States, the manufacturer certifies, or the private labeler unless the manufacturer does 16 CFR 1110.7(b). The CPC is issued on or before the day the product is distributed, and produced within 24 hours when CPSC asks 16 CFR 1110.13(a)(2). Selling only direct to consumers changes nothing, though you need not hand the certificate to buyers CPSC CPC FAQ. The revised certificate content has applied to domestic products since July 8, 2026, without eFiling CPSC update page.
What Small Batch registration changes
You qualify if no more than 7,500 units of the same product were made in the previous year, and your prior-year revenue from all consumer products was no more than a cap set at $1,000,000 in the statute and adjusted each year for inflation 15 U.S.C. 2063(d)(4); the registration page now shows $1,480,296 SaferProducts.gov registration. Registration is valid only for the calendar year in which you register, and your registration number goes on the CPC CPSC small batch FAQ CPSC CPC FAQ.
| Group | Examples | Proof accepted |
|---|---|---|
| A | Lead in paint and coatings (part 1303), small parts (part 1501), lead in children’s metal jewelry, durable infant products, pacifiers | Always a CPSC-accepted lab |
| B | Total lead content of other products, the toy standard ASTM F963, phthalates (part 1307) | In-house tests, a lab not on CPSC’s list or a supplier’s written assurance — otherwise a CPSC-accepted lab |
Both groups: CPSC small batch FAQ. CPSC’s own example is hand-painted wooden toys made at home: the maker may register, but the paint stays a Group A test CPSC online sellers FAQ.
What does not change
You still comply and still prove it; a CPC is required whether or not you register CPSC CPC FAQ. Tracking labels apply whatever the size of the business CPSC tracking label FAQ. Small Batch status is for manufacturers; an importer qualifies only if the foreign factory does too CPSC small batch FAQ. CPSC tells U.S. resellers of secondhand goods they need not test or certify what they resell CPSC online sellers FAQ; importing used goods made after a rule took effect is different, and needs a certificate CPSC eFiling FAQ.
We write CPCs for U.S. makers too, with your Small Batch registration number and the basis for each Group B rule — $79 per product, 2 U.S. business days. There is nothing to eFile for domestic products, so the certificate is the deliverable. Registering with CPSC stays in your hands.
Last reviewed: October 15, 2026 · First published: September 30, 2026 · Not legal advice.
Sources read October 15, 2026
- 16 CFR 1110.7 — Who must certify
- 16 CFR 1110.13 — Certificate availability and eFiling
- CPSC, Children’s Product Certificate (CPC) FAQ
- CPSC, Update: Certificates of Compliance and eFiling
- 15 U.S.C. 2063 — Certificates, third-party testing, tracking labels
- SaferProducts.gov, Small Batch Manufacturer registration (revenue and unit criteria)
- CPSC, Small Batch FAQ (Group A and Group B requirements)
- CPSC, Online Sellers Safety Guide FAQs
- CPSC, Tracking Label FAQ
- CPSC, eFiling Frequently Asked Questions