Compliance
CPSC Compliance Checklist for Children's Apparel Exported to the USA
CPSIA scope, third-party testing, tracking labels, and the exact document set a US customs broker will ask for.
Scope check first
Before anything else, confirm the garment is a "children's product" under CPSIA:
- Marketed as for children ≤12 years old
- Sized in youth sizing
- Depicted in packaging or on labels as for children
If yes, CPSIA applies. If ambiguous, treat as in-scope — the enforcement risk far exceeds the test cost.
The 5 tests every children's garment needs
| Requirement | Limit | Standard |
|---|---|---|
| Total lead in substrate | ≤100 ppm | CPSC-CH-E1002-08.3 |
| Total lead in surface coating | ≤90 ppm | CPSC-CH-E1003-09.1 |
| Phthalates (plasticized parts) | ≤0.1% each | CPSC-CH-C1001-09.4 |
| Flammability | Class 1 (general apparel) | 16 CFR 1610 |
| Drawstrings (upper outerwear, children 2T-16) | No drawstrings in hood/neck; waist drawstrings ≤3in outside garment | 16 CFR 1120 |
Use a CPSC-accepted third-party laboratory (Bureau Veritas, Intertek, SGS, TÜV, MTS). Retain reports for 5 years from the date of manufacture.
Tracking label — non-negotiable
Permanent, distinguishable marking on both the garment (usually stitched-in) and outer packaging showing:
- Manufacturer or private-label brand
- Location (city, state or city, country) of production
- Date of production (month/year is acceptable)
- Cohort or batch identifier
- Any additional information to identify the source
Iron-on and screen-printed tracking labels have failed CPSC field inspections when the print peels — stitched care labels with the tracking info are the safest choice.
The document set for US customs
- Children's Product Certificate (CPC) — issued by the US importer, referencing test reports
- Third-party test reports (lead, phthalates, flammability, drawstring where applicable)
- Component testing documentation if using component-based CPC
- Manufacturing records tying each PO to the tested production batch
- Distribution records for recall traceability
The three mistakes that trigger CBP holds
- Missing CPC — cargo is detained until issued; demurrage costs multiply daily.
- Test report older than the material change — any dye lot, print, or trim change requires re-testing.
- Tracking label date doesn't match production date — CBP treats as fraudulent documentation.
Build the CPC into the pre-shipment checklist alongside AQL sign-off. Never ship without it.
Frequently asked
What is CPSIA and who does it apply to?
The Consumer Product Safety Improvement Act — mandatory for any children apparel product sold in the US and intended for children 12 years or younger. It covers lead content, phthalates in plasticized components, small parts, and drawstrings.
What is a Children Product Certificate?
The CPC is a document (not a physical label) certifying compliance, issued by the importer of record based on CPSC-accepted third-party lab test reports.
Do we need a tracking label on the garment?
Yes — permanent, legible tracking information showing manufacturer, location, production date, and cohort. Required by law even for garments with no other labels.