PortCert
Questions · Which rules apply

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

What it changes, and what it does not

GroupExamplesProof accepted
ALead in paint and coatings (part 1303), small parts (part 1501), lead in children’s metal jewelry, durable infant products, pacifiersAlways a CPSC-accepted lab
BTotal 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.

How PortCert handles this

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.