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CPSIA explained: what it means for children's textiles

The CPSIA governs children's products sold in the US, including clothing and textiles, with lead and phthalate limits, tracking labels and a CPC.

· 3 min read · Creston & Co

The Consumer Product Safety Improvement Act, the CPSIA, is the United States law that sets safety requirements for children's products, and it applies to textiles whenever the product is designed or intended primarily for children aged twelve and under. It is administered by the CPSC, the US federal consumer product safety regulator, and it covers children's clothing, bedding, soft toys and accessories imported from India.

Adult apparel and home textiles are not children's products and sit outside the CPSIA's children's provisions, although other US rules such as flammability standards still apply to them. The practical question for an importer is therefore who the product is for, not what it is made of.

What the CPSIA requires

  • Lead limits for the product and its surface coatings, which affects prints, metal trims, buttons and zips.
  • Phthalate limits, which matter for plastisol prints, coated fabrics and plastic components.
  • Small parts rules for products for young children, affecting buttons, beads, poppers and appliqué.
  • A permanent tracking label that identifies the manufacturer or importer, the production date and location, and a batch reference.
  • A Children's Product Certificate, the CPC, issued by the importer and based on third-party testing at a CPSC-accepted laboratory.

The Children's Product Certificate

The CPC is a document the importer issues, not the lab and not the supplier. It lists the product, each applicable rule, the lab that tested it and the date, and it must be available to customs and the CPSC on request. The testing behind it has to be done at a lab the CPSC has accepted for the specific test, so an ordinary textile lab report may not be enough.

Several of the international labs with Indian operations hold CPSC acceptance for the relevant tests, so the work can be done before shipment. Confirm the lab's acceptance for each test you need, since acceptance is granted test by test. Keep the CPC and the underlying reports together for each production run, because a new run or a change of trim supplier may need fresh testing.

Points importers miss

The CPSC has determined that some untreated and conventionally dyed textiles need not be tested for lead, but screen prints, coatings and trims are not covered by that, and the basis for relying on it should be documented. Tracking labels are often forgotten on garments because the information is spread between the care label and the carton, when it has to be on the product itself.

Requirements and exemptions change, so confirm the current rules with a CPSC-accepted lab or your compliance team before each order. This is general information, not legal advice.

How we help with CPSIA

We agree the CPSIA test plan with you, including which trims and prints need lead and phthalate testing, then draw sealed samples from the bulk and send them to a lab with the right CPSC acceptance. We check the report against your spec and the tracking label on the product before loading, supervise the loading and update you weekly. If you are placing a first children's order from India, we offer a free 20-minute sourcing review.

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