Can an importer use CPSC’s Small Batch Manufacturer program to skip lab tests?
Sometimes. An importer counts as a manufacturer, but CPSC grants Small Batch relief only if both the importer and the foreign factory had prior-year revenue of no more than $1,480,296, and the factory made no more than 7,500 units of the product. Even then, lead in paint and small parts still need a CPSC-accepted lab.
Who qualifies
- The law counts importers as manufacturers 15 U.S.C. 2052(a)(11) and defines a small batch manufacturer by prior-year revenue and units 15 U.S.C. 2063(d)(4).
- CPSC’s reading: an importer qualifies only if it and the manufacturer of the product both meet the criteria; a factory that mass-produces rules it out for that product CPSC small batch FAQ SaferProducts.gov FAQ.
- Revenue: sales of all consumer products in the previous calendar year, affiliated companies included. The registration page shows $1,480,296 SaferProducts.gov registration; some CPSC pages still show the earlier $1,436,864 CPSC small batch FAQ.
- Units: no more than 7,500 of the same product made in the previous calendar year SaferProducts.gov registration.
- Register on SaferProducts.gov before you use the relief 15 U.S.C. 2063(d)(4)(B); a registration lasts for the rest of the calendar year CPSC small batch FAQ.
What it changes, and what it does not
| 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. The CPC and tracking labels still apply CPSC small batch page, and so does eFiling for imports 16 CFR 1110.13(a)(1). CPSC asks for your registration number on the CPC CPSC CPC FAQ.
The eFiling gap
CPSC’s eFiling records carry a Small Batch ID for the manufacturer CATAIR v2.5 Registry guide v3, but for a CPC they accept only CPSC-accepted labs as testing labs, and CPSC’s list of testing exclusion codes has no Small Batch code CPSC code list. We have not found CPSC instructions for filing a Group B result obtained without an accepted lab; CPSC’s Small Business Ombudsman takes questions CPSC Small Business Ombudsman. When a product needs only a few lab tests, the accepted-lab route is often the simpler one.
We write CPCs for registered Small Batch Manufacturers too, with your registration number and the basis for each Group B rule, plus the Registry import file and broker sheet for imports, as far as CPSC’s eFiling tools allow (see above): $79 per certificate, 2 U.S. business days. Registering with CPSC, and confirming that your factory qualifies, stays in your hands.
Last reviewed: October 15, 2026 · First published: October 15, 2026 · Not legal advice.
Sources read October 15, 2026
- 15 U.S.C. 2052(a)(11) — Definition of manufacturer (includes importers)
- 15 U.S.C. 2063 — Certificates, third-party testing, tracking labels
- CPSC, Small Batch FAQ (Group A and Group B requirements)
- SaferProducts.gov, Small Batch Manufacturer FAQ (importers and foreign manufacturers)
- SaferProducts.gov, Small Batch Manufacturer registration (revenue and unit criteria)
- CPSC, Small Batch Manufacturers and third party testing
- 16 CFR 1110.13 — Certificate availability and eFiling
- CPSC, Children’s Product Certificate (CPC) FAQ
- CBP, CPSC eFiling Implementation Guide (CATAIR) v2.5
- CPSC, eFiling Product Registry User Guide v3 (Sept. 22, 2025)
- CPSC, eFiling Citation and Testing Exclusion Codes (Dec. 18, 2025)
- CPSC, Small Business Ombudsman (contact form)