• Deanna Clark-Esposito

CPSC Compliance and Imported Products Not Intended for Children



Importers and the government often take radically opposite positions when it comes to what is considered a children’s product. Given the myriad of extra regulations surrounding goods for children, it is no wonder that importers would want to stay clear of importing them.


The difficulty arises however, when dealing with an article that could be considered attractive to a child. A 3-inch sized colorfully painted object, intended to be merely a decorative household item, could ultimately be considered a toy or children’s product by a government agency. The same holds for a decorative plush good.


While some imports could be considered an obvious decorative household product, such as a wall plaque, and is clearly identifiable as not for a child, others simply do not hold water when it comes to the government’s determination as to it not being a children’s article.


In terms of compliance, any imported article with paint or some other surface coating would be subject to CPSC’s rules and require testing if it is considered a “children’s product” by the government.


In addition to the surface coating issue, when children’s products are involved, there are also lead testing, tracking label and other possible rules, such as that regarding small parts.


Once the testing is complete, then there is the general certificate of conformity requirement that must accompany the shipment attesting to its compliance with the various CPSC rules. This certificate would need to be retained in accordance with Customs record keeping rules and be furnished upon request by Customs and retailers and distributors here in the US.

In addition, if you are planning to have goods shipped into California, or if you have reason to know that they might end up there, it should be noted that the state typically has more stringent rules than those at the national level.


For more information about importation of children’s products, go to www.cpsc.gov.

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