Shipping toys to the United States

A children's toy almost always needs a CPC

Toys are the clearest case in this whole subject, and the least negotiable. The American toy standard is incorporated into federal regulation, it is on the list of rules that require third-party testing, and a certificate is expected for the product rather than for the shipment.

Third-party testing means a laboratory CPSC has accepted, which is the part that costs money and time. It is also the part that cannot be improvised once an order is waiting, so it belongs at the beginning of a product's life rather than at its first American sale.

Citing the standard is not enough

This is the detail that sends certificates back, and it is easy to get right once you know it. A toy certificate must name the individual sections of the toy standard that apply to your toy - the ones about small parts, or about the pull strength of a seam, or about sound levels - rather than pointing at the standard as a whole.

Your laboratory's report already contains those section numbers: they are the lines it tested against. Copying them onto the certificate is a transcription job, not a judgement, and it is the single most common reason a toy certificate is incomplete.

The rules that come with the materials

Beyond the toy standard, four rules follow what the toy is made of, and they apply to a wooden puzzle as readily as to a plastic figure. They are listed separately on CPSC's list, and a certificate names each one that applies.

Small parts deserve a word, because it is a rule about ages rather than about materials: it reaches toys for children under three, and the test is a physical one with a cylinder. A toy that passes for a five-year-old can fail for a two-year-old without anything about it changing.

Collectible toys meant for adults

Not everything that looks like a toy is a children's product. CPSC gives adult collectibles as one of its own examples of a product to which no rule requiring a certificate applies, which is exactly what a Disclaim A is for.

The judgement is yours and it has to survive contact with how you sell the thing: a figurine presented as a toy for children, in a children's category, with a children's age recommendation, is not in this case whatever the box says. And a Disclaim never travels alone - it carries an intended use code.

If you make them yourself, in small numbers

CPSC keeps a register for small batch manufacturers, and registration can lift third-party testing for some rules - not for all of them, and not for the toy standard's core. It is worth checking against your own volumes before assuming the full testing bill applies to you.

Whichever case you are in, the order of work is the same: establish which rules name your toy, get the laboratory report with its section numbers, then write the certificate and register the product so each parcel carries three identifiers instead of a page.

• What a CPC has to say
• The whole procedure, in order
• Registering the product with CPSC