Product Safety Testing


Rhode Island Requiring Children’s Jewelry To Comply With Safety Standard

By Crystal Johnson

On December 31, 2011 the stay of enforcement for third-party testing and certification was lifted. The required testing per the Consumer Product Safety Commission (CPSC) includes total lead content limits in toys and children’s products, certain phthalates for children’s toys and child care articles, and the toy safety standard ASTM F963-08. Those that are small batch manufacturers do have some relief from the testing requirements. Per the CPSC, in order to be considered a small batch manufacturer two items must apply to your business:

  • Earned $1 million or less in total gross revenues from sales of consumer products in 2011
  • Produced in total no more than 7,500 units of at least one consumer product in 2011

If the small batch manufacturer exemption applies to your business then you must register at www.SaferProducts.gov.

Being a small batch manufacturer does not exempt your company from all safety testing. The following third part testing still applies to small batch manufacturers and a certificate is required:

  • Lead-in-paint and other surface coatings, 16 CFR §1303;
  • Full-size cribs and non-full-size cribs, 16 CFR §§1219 and §1220 (pdf);
  • Pacifiers, 16 CFR §1511;
  • Small parts for children under 3 years of age, 16 CFR §1501;
  • Children's metal jewelry, Sec. 101(b) of the CPSIA, as amended by P.L. 112-28; 15 USC 1278a(b)(7) (pdf);
  • Baby bouncers, walkers, and jumpers, 16 CFR §1500.18(a)(6) (pdf) and 16 CFR §1500.86(a) (pdf);
  • Infant Bath Seats, 16 CFR §1215
  • Infant Walkers, 16 CFR §1216 (pdf);
  • Toddler Beds, 16 CFR §1217 (pdf);
  • Other durable infant or toddler products, as additional children's product safety rules are enacted, 15 U.S.C. 2056a(f), Sec. 104 of the CPSIA.

Once your company has registered with the CPSC registry as a small batch manufacturer, the following third party testing does not apply:

  • ASTM F963-08 Toy Safety Standard;
  • Total Lead Content in Children's Products, Sec. 101 of the CPSIA;
  • Ban on certain phthalates in children's toys and certain child care articles, Sec. 108 of the CPSIA;
  • Bicycle helmets, 16 CFR §1203;
  • Bunk beds, 16 CFR §1213 and 1513;
  • Rattles, 16 CFR §1510;
  • Dive sticks, 16 CFR §1500.86 (pdf);
  • Bicycles, 16 CFR §1512;
  • Carpets and rugs, 16 CFR §1630 and §1631;
  • Vinyl plastic film, 16 CFR §1611;
  • Wearing apparel, 16 CFR §1610;
  • Clacker balls, 16 CFR §1500.86 (pdf);
  • Children's sleepwear, 16 CFR §1615 and §1616;
  • Electronically operated toys, 16 CFR §1505;
  • ATVs, 16 CFR. §1420; and
  • Mattresses, 16 CFR §1632

Although small batch manufacturers are exempt from third part testing with regards to the above, they must still confirm that the product complies with the regulations and provide a certificate of conformity. Therefore, in some cases testing will still be required to validate/confirm this.

Please note that some particular states such as California have safety requirements which must be met; therefore, testing to fulfill state requirements may be necessary.

Feel free to contact our lab for additional information regarding testing to meet current and future regulatory requirements. Our laboratory is accredited by the American Association for Laboratory Accreditation (A2LA), certificate number 1888.01 and 1888.02. Additionally, we are a CPSC accredited lab, our laboratory identification number is 1030.

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We are a CPSC accredited lab testing various consumer products for the presence of lead, heavy metals, phthalates, formaldehyde, and other restricted organic compounds.


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Section 108 of the CPSIA specifies that as of February 10, 2009, "it shall be unlawful for any person to manufacture for sale, offer for sale, distribute in commerce, or import into the United States any children’s toy or child care article that contains concentrations of more than 0.1 percent of DEHP, DBP, or BBP.

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