Are rubber or TPR soles on children’s shoes exempt from CPSC lead testing?
No. The word “rubber” in CPSC’s lead determinations, 16 CFR 1500.91(d)(7), names a manufactured textile fiber, such as elastic thread, not a molded sole. A rubber or TPR sole on a children’s shoe must meet the 100 ppm total lead limit, shown by a CPSC-accepted lab test, possibly the supplier’s component test; registered Small Batch Manufacturers have other options.
Where the confusion comes from
CPSC has determined that some materials never exceed the lead limits, as long as nothing that could add lead was added to them 16 CFR 1500.91(d). Item (7) covers textiles made of natural fibers or of manufactured fibers, “dyed or undyed”, “including … rubber, polyester … spandex”, and excludes textiles with treatments other than dyes 16 CFR 1500.91(d)(7). That is rubber as a fiber: an elastic thread or a knitted tape. Leather is exempt under item (8) 16 CFR 1500.91(d)(8). A molded rubber or TPR (thermoplastic rubber) sole fits neither item.
What the sole needs
- Total lead: no more than 100 ppm in each accessible part 15 U.S.C. 1278a CPSC total lead FAQ. A sole is accessible.
- A painted, printed or coated sole surface also meets the 90 ppm lead paint limit 16 CFR part 1303.
- A result covers only material identical in all material respects to the sample tested, whatever its size or shape 16 CFR 1109.5(a)(2). A new compound or pigment needs its own result unless it is shown to be identical in that sense.
- A European soluble-lead test does not replace the total lead requirement CPSC total lead FAQ.
Three ways to show it
| Route | Who tests | Conditions |
|---|---|---|
| Test of the sole at a CPSC-accepted lab | You order it | The lab is accepted for “Lead in Non-Metal Children’s Products” (CPSC-CH-E1002-08) CPSC lab list |
| Supplier’s component test | The sole supplier or the factory, at a CPSC-accepted lab | Traceable to your soles, with the documents listed in the rule, and due care on your side 16 CFR 1109.12 16 CFR 1109.5(g) |
| Registered Small Batch Manufacturer | In-house test, a lab not on CPSC’s list, or a supplier’s written assurance | Total lead is a Group B rule; an importer qualifies only if the factory also does. Lead in paint is Group A: still a CPSC-accepted lab CPSC small batch FAQ |
On the Small Batch route, CPSC’s eFiling tools still raise a practical question, covered in our page on Small Batch for importers.
You can order the test or collect your supplier’s reports yourself. If you would rather not, send us your factory’s materials list and any sole test reports: we check each report against the rule, the lab’s CPSC acceptance and the material it covers, then write the CPC, the Registry import file and the broker sheet. $79 per certificate, 2 U.S. business days. We do not test products.
Last reviewed: October 19, 2026 · First published: October 19, 2026 · Not legal advice.
Sources read October 19, 2026
- 16 CFR 1500.91(d)(7) — Lead content determination for textiles
- 16 CFR 1500.91(d)(8) — Lead content determination for leather and other animal- or plant-derived materials
- 15 U.S.C. 1278a — Lead limits in children’s products
- CPSC, FAQ: Total Lead Content (relying on suppliers; European soluble-lead tests)
- 16 CFR part 1303 — Lead in paint and similar surface coatings
- 16 CFR 1109.5 — Relying on another party’s tests or certificates (due care, documentation)
- CPSC, list of CPSC-accepted testing laboratories
- 16 CFR 1109.12 — Component part testing for lead content of children’s products
- CPSC, Small Batch FAQ (Group A and Group B requirements)