Shipping baby products to the United States

Everything here is a children's product

Baby goods leave no room for the question that occupies clothing and jewellery sellers. A product designed or intended primarily for children twelve or younger is a children's product, and a pram, a bottle or a cot is nothing else.

The consequence is immediate: the certificate is a CPC, and the testing behind it comes from a laboratory CPSC has accepted. There is no fabric threshold to check and no enforcement discretion to fall back on, which at least makes the planning simple.

Each family of product has its own rule

This is what makes baby goods different from the other trades: the rules are specific to the object rather than to the material. Full-size cribs, strollers, high chairs, sling carriers, pacifiers, nursing pillows - each has its own part of title 16, with its own test method and its own citation to put on the certificate.

Two practical consequences follow. First, a certificate cannot be copied from one product to the next in your catalogue, because the citation changes with the object. Second, a change of model usually means a new test rather than a new sentence: these standards are about the object's behaviour, and a redesigned frame is a different object.

It also explains why a supplier's blanket assurance is not usable here. A factory that says its goods meet American requirements has said nothing you can put on a certificate: the certificate names a part of title 16 and a laboratory, and it is the specific object that was tested.

And the rules that follow the materials

On top of the object's own rule come the ones that apply to anything a small child handles: total lead content, lead in surface coatings, phthalates in plastics, and small parts for the youngest ages. A wooden teether with a painted face is touched by three of them at once.

Each rule that applies is named separately on the certificate. That is not a stylistic preference: a certificate that says the product complies with the applicable requirements identifies nothing, and the eFiled data is built from those citations.

Planning it so a launch does not slip

The laboratory is the long pole. Everything else - the account, the certificate, the registration, the annex - is an afternoon. So the order that works is: identify the rules for the object, book the testing, and use the waiting time for the administrative half.

• List each model you actually ship to the United States, not the whole catalogue.
• For each, the rule that names it, plus lead, phthalates and small parts where they apply.
• The laboratory's name, address and test date, and confirmation that CPSC accepts it.
• A Registry entry per model, so each parcel carries identifiers rather than a page.

Our questions go through exactly that, model by model, and produce the certificate with its citations laid out the way the regulation asks. Where a rule does not apply, they say so rather than adding it for safety.

• The whole procedure, in order
• Registering a product with CPSC
• The guide for toys