Your map: a puzzle or game built as declared
This is a conditional reading of published rules against the facts declared on the scan page. No physical product was evaluated, and nothing here is a legal or regulatory determination — every row names the declared fact that pulls it in and links the primary text it is read from.
This map reads a puzzle or game. Category maps for other product types are added as they are built. Run the free scan for any category.
The input: the facts this map reads
Carried over from the scan page when answered there; adjust any answer here and the map re-reads instantly. Answers stay in this browser.
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1. Which published rules reach a product built this way
Each row names a rule, quotes the sentence that does the work, links the primary text, and says which of the eight facts pulled it in. Nothing was measured; this is what the published rules say for that combination of age, material and construction.
CPSC is not the only writer here. Customs marking, California, Maine, Oregon and Connecticut sit in the same sequence rather than an appendix, because a shipment meets them in the same sequence.
16 CFR part 1303
Requirement Ban of Lead-Containing Paint and Certain Consumer Products Bearing Lead-Containing Paint · CPSC · pulled in by the paint
Lead in a surface coating on a children's article is capped at 0.009 percent — 90 ppm — of the dried film, and a toy bearing paint above that is a banned hazardous product.
“paint … for consumer use that contain lead … in excess of 0.06 percent (0.06 percent is reduced to 0.009 percent effective August 14, 2009 …) of the weight of the total nonvolatile content of the paint or the weight of the dried paint film … are banned hazardous products … (1) Toys and other articles intended for use by children that bear “lead-containing paint”.”
16 CFR 1303.1(a), eCFR
Why here. One fact does it: the toy is for children and it bears a coating. 16 CFR 1303.2(b)(1) draws the boundary around a material that turns into a solid film on the surface, which a lacquer, varnish or printed coating does and a stain that soaks in may not; only the coating's data sheet says which. The exemptions at 1303.3 cover farm coatings, traffic paint and artists' colours — none covers a children's toy.
16 CFR part 1303
Requirement Ban of Lead-Containing Paint and Certain Consumer Products Bearing Lead-Containing Paint · CPSC · pulled in by the coating, if there is one
Lead in a surface coating on a children's article is capped at 0.009 percent — 90 ppm — of the dried film, and a toy bearing paint above that is a banned hazardous product.
“paint … for consumer use that contain lead … in excess of 0.06 percent (0.06 percent is reduced to 0.009 percent effective August 14, 2009 …) of the weight of the total nonvolatile content of the paint or the weight of the dried paint film … are banned hazardous products … (1) Toys and other articles intended for use by children that bear “lead-containing paint”.”
16 CFR 1303.1(a), eCFR
Why here. Declared as not sure whether the surface is coated. This ban reaches a coating and nothing else, which is why the coating question is the first fact worth settling: it decides whether this row carries a laboratory bill at all. 16 CFR 1303.2(b)(1) draws the boundary around a material that turns into a solid film on the surface — a printed ink layer on a piece is a question for the coating's or ink's data sheet, not for guesswork.
15 U.S.C. 1278a
Requirement Children's products containing lead; lead paint rule · CPSC · pulled in by the age grading
Total lead is capped at 100 ppm, written against any part of a children's product: wood, coating, adhesive and label are each measured on their own.
“beginning on the date that is 3 years after August 14, 2008, subparagraph (B) shall be applied by substituting “100 parts per million” for “300 parts per million” …”
15 U.S.C. 1278a(a)(2)(C), govinfo
Why here. The declared age band sits inside “12 years of age or younger”, so the cap reaches a product built this way. Part-by-part is what matters: each piece, the board, an ink layer, an adhesive and a label are measured on their own, and a thin coating cannot be diluted into the weight of the piece under it.
15 U.S.C. 1278a
Requirement Children's products containing lead; lead paint rule · CPSC · pulled in by the age grading
Total lead is capped at 100 ppm, written against any part of a children's product: wood, coating, adhesive and label are each measured on their own.
“beginning on the date that is 3 years after August 14, 2008, subparagraph (B) shall be applied by substituting “100 parts per million” for “300 parts per million” …”
15 U.S.C. 1278a(a)(2)(C), govinfo
Why here. A grading of 12 years or older sits on the boundary itself: CPSC's children's-product definition is 12 years of age or younger, so the grading — read together with marketing and common recognition, not the label alone — decides whether this cap reaches the product at all. The definition is worth reading directly rather than assuming either way.
15 U.S.C. 1278a
Requirement Children's products containing lead; lead paint rule · CPSC · pulled in by the age grading
Total lead is capped at 100 ppm, written against any part of a children's product: wood, coating, adhesive and label are each measured on their own.
“beginning on the date that is 3 years after August 14, 2008, subparagraph (B) shall be applied by substituting “100 parts per million” for “300 parts per million” …”
15 U.S.C. 1278a(a)(2)(C), govinfo
Why here. No age grading has been declared yet. The cap is written against children's products — 12 years of age or younger — so the grading, once chosen, carries this row with it. That choice is made on the artwork and the packaging, not in a laboratory.
16 CFR 1500.91(d)(4)
Relief Determinations regarding lead content for certain materials or products under section 101 of the CPSIA · CPSC · pulled in by the wood
Wood is determined to be within the total lead limit, so the wood need not go to a laboratory for it. The limit itself is untouched.
“The following materials do not exceed the lead content limits under section 101(a) of the CPSIA provided that these materials have neither been treated or adulterated … : … (4) Wood.”
16 CFR 1500.91(d), eCFR
“Paint, coatings or electroplating may not be considered a barrier that would make the lead content of a product inaccessible to a child.”
16 CFR 1500.91(a), eCFR
Why here. Paragraph (d)(4) is the single word “Wood”, with no qualifier about finish. That is why the substrate leaves the lead bill entirely — and why what is painted on top of it does not.
16 CFR part 1252
Relief Determinations regarding lead, ASTM F963 elements and phthalates for engineered wood products · CPSC · pulled in by the engineered wood
Part 1252 records where CPSC concluded certain engineered wood materials need not be tested for lead, the toy standard's elements, or phthalates. Which board types it covers, and on what conditions, is written in the part itself — the limits are untouched either way.
“CPSC has also issued determinations stating that products with certain characteristics may not require testing and/or certification.”
CPSC, Children's Product Certificate
Why here. Declared as engineered wood, the bare-wood determinations stop fitting: 16 CFR 1500.91(d)(4) is the single word “Wood”, and 16 CFR 1251.2(b) expressly excludes manufactured or engineered woods. Part 1252 is where the engineered-wood determinations live instead, and reading its conditions directly is the only way to know which apply to a given board. CPSC states the general principle on its certificate page.
16 CFR part 1307
Requirement Prohibition of Children's Toys and Child Care Articles Containing Specified Phthalates · CPSC · pulled in by being a children's toy
Eight phthalates — DEHP, DBP, BBP, DINP, DIBP, DPENP, DHEXP and DCHP — are each capped at 0.1 percent, measured against component parts.
“the restrictions … apply to any plasticized component part of a children's toy … or any other component part … that is made of other materials that may contain phthalates.”
16 CFR 1307.3(c), eCFR
Why here. It is a children's toy. Paragraph (c) reaches any plasticized component part and any component made of other materials that may contain phthalates — a plastic pawn, a printed coating and a glue line all come into scope. Separate determinations for specified plastics exist at 16 CFR part 1308 and carry their own material conditions; they are not read on this page.
76 FR 49286, footnote 2
Relief Notice of Requirements for accreditation to assess conformity with the limits on phthalates in children's toys and child care articles · CPSC · pulled in by the wood
Untreated and unfinished wood is not expected to contain phthalates and need not be tested or certified for them, provided nothing was added that could introduce them.
“Untreated/unfinished wood, metal, natural fibers, natural latex and mineral products are not expected to inherently contain phthalates and need not be tested or certified provided that these materials have neither been treated or adulterated …”
76 FR 49286 n.2 (2011-08-10), Federal Register
“Natural wood, except for coatings and adhesives added to wood”
CPSC, Statement of Policy: Testing of Component Parts
Why here. Where this relief lives is the point. There is no phthalate determination for solid wood anywhere in 16 CFR. It sits in a Federal Register notice and a Commission policy statement: primary and published, but with no CFR paragraph to name on a certificate.
16 CFR part 1250
Requirement Safety Standard for Toys (ASTM F963-23) · CPSC · pulled in by being a toy
Every toy meets the applicable provisions of ASTM F963-23, the version incorporated at 16 CFR 1250.10 and, per CPSC, the one governing toys made on or after 20 April 2024.
“(a) Each toy must comply with all applicable provisions of ASTM F963-23 … (b) … section 4.2 and Annex 5 or any provision of ASTM F963 that restates or incorporates an existing mandatory standard or ban … are not part of the mandatory standard incorporated in paragraph (a).”
16 CFR 1250.2, eCFR
Why here. It is a toy, and which sections bite is decided by what it physically is — the declared surface, features and construction. Paragraph (b) is the piece secondary write-ups drop — 4.2, Flammability, and Annex 5 are not part of the mandatory standard. Flammability does not vanish; it moves, to its own row below.
16 CFR 1251.2
Relief Toys: Determinations Regarding Heavy Elements Limits for Certain Materials · CPSC · pulled in by the bare wood surfaces
Unfinished and untreated wood is determined to meet the toy standard's heavy-element limits — and the definition of that wood excludes coated surfaces.
“unfinished and untreated wood means wood harvested from the trunks of trees with no added surface coatings (such as, varnish, paint, shellac, or polyurethane) and no materials added to the wood substrate … does not include manufactured or engineered woods …”
16 CFR 1251.2(b), eCFR
Why here. On wood left bare, the definition is answerable: no added surface coatings. The relief attaches, and the toy standard's heavy-element bill for those surfaces leaves the laboratory. Leaving faces bare is decided on the drawing.
16 CFR 1251.2
Relief Toys: Determinations Regarding Heavy Elements Limits for Certain Materials · CPSC · pulled in by the bare faces only
Unfinished and untreated wood is determined to meet the toy standard's heavy-element limits — and the definition of that wood excludes coated surfaces.
“unfinished and untreated wood means wood harvested from the trunks of trees with no added surface coatings (such as, varnish, paint, shellac, or polyurethane) and no materials added to the wood substrate … does not include manufactured or engineered woods …”
16 CFR 1251.2(b), eCFR
Why here. The lead determination above is the bare word “Wood”; this one spells out no added surface coatings and names varnish and paint. On the declared build — some faces coated, some bare — the relief attaches only to the bare faces, while every coated face stays in the laboratory's scope. Which faces get coated is decided on the drawing, and on a wooden build it is the largest cost lever on this page.
16 CFR 1251.2
Relief Toys: Determinations Regarding Heavy Elements Limits for Certain Materials · CPSC · pulled in by unpainted wood only — which this build does not declare
Unfinished and untreated wood is determined to meet the toy standard's heavy-element limits — and the definition of that wood excludes coated surfaces.
“unfinished and untreated wood means wood harvested from the trunks of trees with no added surface coatings (such as, varnish, paint, shellac, or polyurethane) and no materials added to the wood substrate … does not include manufactured or engineered woods …”
16 CFR 1251.2(b), eCFR
Why here. The lead determination above is the bare word “Wood”. This one spells out no added surface coatings and names varnish and paint. On a toy coated on every face nothing answers to the definition, so this relief does not attach while the lead one still does. Leaving faces bare is decided on the drawing.
16 CFR 1501.3, with the exception clause of 16 CFR 1500.19(b)(1)
Relief The exemption list that decides whether the small-parts rows bite at all · CPSC · pulled in by what the pieces are made of, and what is bundled in the box
Ten article types — balloons, paper articles, writing materials such as crayons, chalk, pencils and pens, modeling clay, fingerpaints, watercolors and other paint sets among them — are exempt from the under-3 small-parts ban, and the 3-to-under-6 choking label excepts the same list. Balloons are carved back in: exempt from the ban, they keep their own label at any age.
“The following articles are exempt from this regulation (§§ 1500.18(a)(9) and 1501.4 below): (a) Balloons; (b) Books and other articles made of paper; (c) Writing materials such as crayons, chalk, pencils, and pens; (d) Children's clothing and accessories, such as shoe lace holders and buttons; (e) Grooming, feeding, and hygiene products, such as diaper pins and clips, barrettes, toothbrushes, drinking glasses, dishes and eating utensils; (f) Phonograph records; (g) Modeling clay and similar products; (h) Fingerpaints, watercolors, and other paint sets; (i) Rattles (as defined at 16 CFR 1510.2); and (j) Pacifiers (as defined at 16 CFR 1511.2(a)).”
16 CFR 1501.3, eCFR
“With the exception of books and other articles made of paper, writing materials such as crayons, chalk, pencils, and pens, modeling clay and similar products, fingerpaints, watercolors, and other paint sets, and any other article identified in 16 CFR 1501.3 (other than balloons), any article that is a toy or game intended for use by children who are at least three years old but less than six years of age shall bear or contain the following cautionary statement if the toy or game includes a small part:”
16 CFR 1500.19(b)(1), eCFR
“the Commission is revising the final labeling rule under the CSPA to clarify that products containing small parts and intended for children at least three years of age but less than six years old, are exempt from the labeling requirements if the same products, when intended for children under three, would be exempt from the small parts banning regulation. This labeling exemption does not, however, apply to balloons, which the CSPA expressly requires to bear precautionary labeling. 15 U.S.C. 1278(b)(1).”
60 FR 41801 (1995-08-14), Federal Register
Why here. The load-bearing row of this category: where a piece sits against this list decides whether the ban and label rows below carry any weight. The boundary the list does not draw is the one a jigsaw seller needs — the regulation says paper, not paperboard or cardboard, and no primary text read for this page settles where paper ends. The 1995 rule's original wording excepted paper products such as punch-out games, and the ban's own test procedure never counts detached paper — support for the paper reading that stops short of die-cut board. The conservative reading treats a cardboard jigsaw marketed for under-3 as inside the ban unless the articles-made-of-paper reading can be defended.
16 CFR part 1501 and 16 CFR 1500.18(a)(9)
Requirement Method for Identifying Toys and Other Articles Intended for Use by Children Under 3 Years of Age Which Present Choking, Aspiration, or Ingestion Hazards Because of Small Parts · CPSC · pulled in by the age grading, and the shape
A toy for children under 3 that yields a small part — one fitting whole into CPSC's 2.25 by 1.25 inch cylinder, before or after use and abuse conditioning — is a banned hazardous substance.
“Such articles include, but are not to limited to: … preschool toys, games and puzzles intended for use by children under 3; …”
16 CFR 1501.2(a), eCFR
Why here. Two ways in, both closed: the age grading puts it under 3, and the rule's own list names preschool games and puzzles outright. Every die, pawn, token and puzzle knob answers to the cylinder — and the fragments the test excuses are paper, fabric, yarn, fuzz, elastic and string, a list that does not reach a wooden or plastic piece.
16 CFR part 1501 and 16 CFR 1500.18(a)(9)
Requirement Method for Identifying Toys and Other Articles Intended for Use by Children Under 3 Years of Age Which Present Choking, Aspiration, or Ingestion Hazards Because of Small Parts · CPSC · pulled in by the age grading, once decided
A toy for children under 3 that yields a small part — one fitting whole into CPSC's 2.25 by 1.25 inch cylinder, before or after use and abuse conditioning — is a banned hazardous substance.
“Such articles include, but are not to limited to: … preschool toys, games and puzzles intended for use by children under 3; …”
16 CFR 1501.2(a), eCFR
“In determining which toys and other articles are intended for use by children under 3 years (36 months) of age, for purposes of this regulation, the following factors are relevant: the manufacturer's stated intent (such as on a label) if it is a reasonable one; the advertising, promotion, and marketing of the article; and whether the article is commonly recognized as being intended for children under 3.”
16 CFR 1501.2(b), eCFR
Why here. If the grading lands under 3 — or the game is marketed in a way commonly recognised as for under-3s — this ban reaches it, and the rule's own list names preschool games and puzzles outright. The rule's factors make the stated age relevant only if it is a reasonable one, alongside advertising and common recognition, so the grading decision carries this whole row with it.
16 CFR 1500.19(b)(1) with 15 U.S.C. 1278
Requirement Cautionary labeling for small parts (toys and games for ages 3 to under 6) · CPSC · pulled in by the age grading
A toy or game for children at least 3 but under 6 that includes a small part carries the small-parts choking warning on its packaging and accompanying material; without it the toy is a misbranded hazardous substance.
“any article that is a toy or game intended for use by children who are at least three years old but less than six years of age shall bear or contain the following cautionary statement if the toy or game includes a small part:”
16 CFR 1500.19(b)(1), eCFR
“WARNING: CHOKING HAZARD--Small parts. Not for children under 3 yrs.”
16 CFR 1500.19(b)(1) statement, transcribed from the official CFR PDF, govinfo
Why here. Above the under-3 line the small-parts ban falls away and a label duty takes its place: the same test cylinder decides, but on the article as sold, and the answer becomes required wording on the box rather than a ban. The rule opens with its own exception list — paper articles, crayons and other writing materials, modeling clay and paint sets are excepted along with the rest of 16 CFR 1501.3, except balloons, which keep their own label. The statement, its triangle, and the type sizes are set out in the regulation as a published table — not a design choice.
16 CFR 1501.4(b) with 16 CFR 1500.19(a)(5)
Requirement Two test procedures for one cylinder: the ban conditions the article, the label reads it as sold · CPSC · pulled in by the age grading, and how the pieces are fixed
The under-3 ban counts pieces liberated by the use and abuse conditioning of 16 CFR 1500.51 and 1500.52; the 3-to-under-6 label counts only what fits the cylinder as sold, because 16 CFR 1500.19(a)(5) reads the use-and-abuse steps out of its small-part definition.
“Any components or pieces (excluding paper, fabric, yarn, fuzz, elastic, and string) which have become detached from the article as a result of the use and abuse testing shall be placed into the cylinder, one at a time. If any such components or pieces fit entirely within the cylinder, in any orientation and without being compressed, the article fails to comply with the test procedure.”
16 CFR 1501.4(b)(2), eCFR
“Small part means any object which, when tested in accordance with the procedures contained in 16 CFR 1501.4(a) and 1501.4(b)(1), fits entirely within the cylinder shown in Figure 1 appended to 16 CFR part 1501. The use and abuse testing provisions of 16 CFR 1500.51 through 1500.53 and 1501.4(b)(2) do not apply to this definition.”
16 CFR 1500.19(a)(5), eCFR
Why here. The same knob can pass one regime and not the other. A glued knob on a peg puzzle, or a pawn on a stand, that stays whole in the box but comes off in conditioning makes an under-3 article banned — while the 3-to-under-6 label, judged on the article as sold, is not triggered by a piece that only becomes small when broken off. One carve-out sits inside the ban's own procedure: detached paper, fabric, yarn, fuzz, elastic and string are never counted.
16 CFR 1500.18(a)(17)
Requirement Ban of small balls intended for children under three · CPSC · pulled in by a ball among the pieces, and the age grading
A game containing a small ball — one that passes through a 1.75 inch circular template — and intended for children under 3 is a banned hazardous substance. A label does not cure it; a tethered ball is still a ball; dice are expressly excluded from the definition.
“Any ball intended for children under three years of age that, under the influence of its own weight, passes, in any orientation, entirely through a circular hole with a diameter of 1.75 inches (44.4 mm.) in a rigid template 1/4 inches (6 mm.) thick.”
16 CFR 1500.18(a)(17), eCFR
“The term "ball" includes any spherical, ovoid, or ellipsoidal object that is attached to a toy or article by means of a string, elastic cord, or similar tether.”
16 CFR 1500.18(a)(17)(i), eCFR
“The term "ball" does not include dice, or balls permanently enclosed inside pinball machines, mazes, or similar outer containers.”
16 CFR 1500.18(a)(17)(ii), eCFR
“Marble means a ball made of a hard material, such as glass, agate, marble or plastic, that is used in various children's games, generally as a playing piece or marker.”
16 CFR 1500.19(a)(4), eCFR
Why here. This ban is separate from the small-parts row above and measures differently: the ball template is 1.75 inches wide against the cylinder's 1.25, so a ball can clear the small-parts test and still be banned here. Marbles are the open edge: no standalone marble ban paragraph exists in 16 CFR 1500.18, the definitions read a marble as a ball made of a hard material that is rolled, and the exclusion list names only dice and permanently enclosed balls — but no primary text applies this ban to marbles expressly, and the labeling scheme treats balls and marbles as separate categories, so that reading stands as an interpretation question. For an under-3 game the outcome does not turn on it: a marble fits the small-parts cylinder, and the small-parts ban reaches it either way.
16 CFR 1500.19(b)(3) and (b)(4), with 15 U.S.C. 1278(b)(1)
Requirement Cautionary labeling for small balls and marbles — and games containing them · CPSC · pulled in by a ball or marble among the pieces
A toy or game for children at least 3 but under 8 that contains a small ball or a marble carries the ball or marble choking statement; a small ball or marble sold on its own is labeled from age 3 with no upper age bound in the statute.
“Any toy or game intended for children who are at least three years old but less than eight years of age that contains a small ball shall bear the following cautionary statement:”
16 CFR 1500.19(b)(3)(ii), eCFR
“Any toy or game intended for children who are at least three years old but less than eight years of age that contains a marble shall bear the following cautionary statement:”
16 CFR 1500.19(b)(4)(ii), eCFR
“In the case of any latex balloon, any ball with a diameter of 1.75 inches or less intended for children 3 years of age or older, any marble intended for children 3 years of age or older, or any toy or game which contains such a balloon, ball, or marble … the packaging of such balloon, ball, marble, toy, or game … shall bear or contain the cautionary statement described in paragraph (2).”
15 U.S.C. 1278(b)(1), govinfo
Why here. These labels outrun the familiar 3-to-under-6 small-parts label: the game trigger runs to under eight, and the statute's own trigger for a standalone ball or marble is simply intended for children 3 years of age or older. A grading of 6 to 11 that has left the small-parts label behind can still carry this one. The statements themselves are set out in the regulation's own labeled boxes.
16 CFR 1500.14(b)(8) (LHAMA, ASTM D-4236)
Requirement Labeling of art materials bundled with a game or puzzle · CPSC · pulled in by bundled crayons, paints or other art materials, where present
A game that includes crayons, paints, markers or modeling compound — a color-your-own puzzle, a drawing game — carries the LHAMA duty on those components: a chronic-hazard labeling review to ASTM D-4236 and a conformance statement, for users of any age.
“The standard referred to in paragraph (b)(8)(i) of this section applies to art materials intended for users of any age.”
16 CFR 1500.14(b)(8)(ii)(B), eCFR
“The term art material or art material product shall mean any substance marketed or represented by the producer or repackager as suitable for use in any phase of the creation of any work of visual or graphic art of any medium.”
16 CFR 1500.14(b)(8)(ii)(A), eCFR
“Statement of Conformance—"Conforms to ASTM Practice D-4236," or "Conforms to ASTM D-4236," or "Conforms to the health requirements of ASTM D-4236." This statement may be combined with other conformance statements.”
16 CFR 1500.14(b)(8)(i)(C)(7), eCFR
Why here. This duty runs on its own track. The same crayons and paint sets that 16 CFR 1501.3 exempts from the small-parts ban, and that the choking label excepts, are squarely inside LHAMA — the exemption lists and this rule simply never meet. The scope clause is written against users of any age, so an adult grading changes nothing here. A game with no art materials in the box has nothing for this row to act on.
15 U.S.C. 2052(a)(2), with 16 CFR 1250.1 and 1250.2
Requirement The children's-product line at 12 — and the toy standard's own line at 14 · CPSC · pulled in by the age grading
Whether the children's-product obligations attach — third-party testing, the certificate, the tracking label, the children's lead and phthalate limits — is judged on the statute's four factors, not the box age alone. The toy standard's own definition, as CPSC quotes it, covers playthings for children under 14.
“The term "children's product" means a consumer product designed or intended primarily for children 12 years of age or younger. In determining whether a consumer product is primarily intended for a child 12 years of age or younger, the following factors shall be considered: (A) A statement by a manufacturer about the intended use of such product, including a label on such product if such statement is reasonable. (B) Whether the product is represented in its packaging, display, promotion, or advertising as appropriate for use by children 12 years of age or younger. (C) Whether the product is commonly recognized by consumers as being intended for use by a child 12 years of age or younger. (D) The Age Determination Guidelines issued by the Commission staff in September 2002, and any successor to such guidelines.”
15 U.S.C. 2052(a)(2), govinfo
“A toy is 'any object designed, manufactured, or marketed as a plaything for children under 14 years of age.' 16 CFR 1250.2(a); section 3.1.92 of ASTM F963-23.”
89 FR 73024 (2024-09-09), Federal Register
“Because toys are children's products, a CPSC-accepted third-party conformity assessment body must test samples of the products.”
89 FR 3350 (2024-01-18), Federal Register
Why here. A hobby game graded 14 and over sits outside both lines only if the grading holds up: packaging imagery, marketing and common recognition are statutory factors, so a cartoon theme or family-night promotion can pull a nominally adult game back in. The two definitions also do not meet at the same age — 12 or younger against under 14 — and whether a game graded for 13-year-olds answers to the toy standard without the children's-product machinery is not resolved by any primary text we found; CPSC's own rule preamble states that toys are children's products without addressing the band. We say so rather than guessing.
ASTM F963-23 sections 4.7 to 4.40, via 16 CFR 1250.2(a)
Requirement The toy standard's sections for game hardware — boards, spinners, hinges and knobs · CPSC · pulled in by the hardware the build actually has
A game board with a folding leg answers to section 4.13, Folding Mechanisms and Hinges; a die-cut board or metal tin to 4.7, Accessible Edges; a spinner arrow to 4.9, Accessible Points, and its spindle to 4.10, Wires or Rods; film windows and packaging film to 4.12, Plastic Film; a child-size game table to 4.15, Stability and Overload; knobs on a knob puzzle to 4.32, Certain Toys with Nearly Spherical Ends, and dome-shaped pieces to 4.36, Hemispheric-Shaped Objects; water-swelling components to 4.40, Expanding Materials — each on the third-party testing list where the hardware exists.
“(M) Section 4.13, Folding Mechanisms and Hinges”
16 CFR 1112.15(b)(32)(ii), eCFR
“(DD) Section 4.32, Certain Toys with Nearly Spherical Ends”
16 CFR 1112.15(b)(32)(ii), eCFR
“(FF) Section 4.36, Hemispheric-Shaped Objects”
16 CFR 1112.15(b)(32)(ii), eCFR
“(JJ) Section 4.40, Expanding Materials”
16 CFR 1112.15(b)(32)(ii), eCFR
Why here. None of these sections attaches by category; each attaches to a piece of hardware the declared build may or may not have, and a game with none of it has nothing for these sections to act on. What public primary sources establish is the section numbers, titles and third-party status — the CFR's own testing list — while the numeric requirements sit in ASTM's copyrighted text. A toy containing water-absorbing polymer beads also answers to 16 CFR 1250.4's own performance and labeling requirements for water beads.
15 U.S.C. 2063(a)(5)(A)
Requirement Tracking labels on children's products (CPSIA section 103) · CPSC · pulled in by the age grading
Permanent distinguishing marks go on the product and on its packaging: enough to trace place, date and cohort, and enough for the buyer to read them.
“the manufacturer of a children's product shall place permanent, distinguishing marks on the product and its packaging, to the extent practicable, that will enable— (i) the manufacturer … and (ii) the ultimate purchaser to ascertain the manufacturer or private labeler, location and date of production, and cohort information …”
15 U.S.C. 2063(a)(5)(A), govinfo
Why here. It follows from being a children's product and nothing else. CPSC states this is not assessed by a third party laboratory and asks for no citation to it on the certificate — the cheapest line here and one of the most missed.
15 U.S.C. 1261(q)(1)(A) with 16 CFR 1500.3(c)(6)(vi) and 1500.44
Requirement Flammable solids as banned hazardous substances (FHSA) · CPSC · pulled in by being a toy
A toy that is a hazardous substance is a banned hazardous substance, and a flammable solid is defined by a burn rate faster than a tenth of an inch per second, by the candle method at 16 CFR 1500.44.
“Flammable solid means a solid substance that, when tested by the method described in § 1500.44, ignites and burns with a self-sustained flame at a rate greater than one-tenth of an inch per second along its major axis.”
16 CFR 1500.3(c)(6)(vi), eCFR
Why here. This row corrects a widely repeated mistake rather than raising a bill. Flammability is not reached through ASTM F963 section 4.2, because 16 CFR 1250.2(b) takes 4.2 out of the mandatory standard. It is reached here, where 16 CFR 1112.15(b) carries no line for it — so no accredited scope exists, and the prohibition is still live.
16 CFR part 1263, with 15 U.S.C. 2056e (Reese's Law)
Requirement Safety Standard for Button Cell or Coin Batteries and Consumer Products Containing Such Batteries · CPSC · pulled in by the button or coin battery
A product containing or designed to use a button or coin battery meets ANSI/UL 4200A-2023 and its warning scheme — unless it is a toy that complies with the toy standard's battery accessibility and labeling requirements. The exemption is conditional, not categorical.
“Exemption for toy products. Any object designed, manufactured, or marketed as a plaything for children under 14 years of age that is in compliance with the battery accessibility and labeling requirements of 16 CFR part 1250 is exempt from the requirements of this part.”
16 CFR 1263.1(c), eCFR
“(Z) Section 4.25, Battery-Operated Toys (except labeling and/or instructional literature requirements)”
16 CFR 1112.15(b)(32)(ii), eCFR
Why here. The exemption is the sentence to read twice: it holds only while the toy complies with the battery accessibility and labeling requirements of 16 CFR part 1250 — ASTM F963-23's battery sections, which are third-party tested. A toy that fails them falls into part 1263 and UL 4200A. One battery duty sits outside the exemption's wording entirely: since February 12, 2023, Reese's Law section 3 requires child-resistant packaging under 16 CFR 1700.15 and 1700.20 for button or coin batteries sold or included separately with a product, and CPSC calls that section self-implementing. Whether the toy exemption shields a battery packaged separately with an exempt toy is not settled by any primary text we found — we say so rather than guessing.
16 CFR 1262.1(c), routing into 16 CFR part 1250
Requirement Safety Standard for Magnets — and the toy exclusion that routes a toy's magnets into the toy standard · CPSC · pulled in by the magnets
A toy with magnets is exempt from the general magnet standard and answers instead to the toy standard's magnet section, ASTM F963-23 section 4.38 — tested at a CPSC-accepted laboratory.
“Exemption. The following consumer products are exempt from the requirements of this part: Toys that are subject to 16 CFR part 1250.”
16 CFR 1262.1(c), eCFR
“(HH) Section 4.38, Magnets (except labeling and/or instructional literature requirements)”
16 CFR 1112.15(b)(32)(ii), eCFR
Why here. Two rules could claim a magnet, and the CFR itself sorts them: toys subject to part 1250 are exempt from part 1262 because, in the Commission's words, the toy standard already addresses the magnet ingestion hazard. What section 4.38 demands sits in ASTM's copyrighted text; what public primary sources establish is its number, its third-party-testing status, and CPSC's own description — a hazardous magnet is one that fits the small-parts cylinder with a flux index of 50 kG²mm² or more, as received or after use-and-abuse testing.
ASTM F963-23 sections 4.25 and 4.5, via 16 CFR 1250.2(a)
Requirement Battery-operated and sound-producing toys — and where the electrical rules end · CPSC · pulled in by the electronics and sound
The toy standard's battery section (accessibility, overheating, chargers) and sound section (sound-pressure limits) apply and are third-party tested. The separate mains-voltage rule at 16 CFR part 1505 reaches only toys powered from 120-volt branch circuits.
“This definition does not include components which are powered by circuits of 30 volts r.m.s. (42.4 volts peak) or less, articles designed primarily for use by adults which may be used incidentally by children, or video games.”
16 CFR 1505.1(a)(1), eCFR
“(E) Section 4.5, Sound Producing Toys”
16 CFR 1112.15(b)(32)(ii), eCFR
Why here. Boundaries do the work here. Part 1505's own scope excludes circuits of 30 volts or less, so a battery-only toy answers to the toy standard's sections 4.25 and 4.5 instead — both on the third-party list. And one boundary leaves CPSC entirely: radio-frequency emissions of an electronic module belong to the FCC under 47 CFR part 15, an authorization regime this page only points at, because it is another agency's subject and turns on design facts a declaration cannot settle.
ASTM F963-23 section 4.14, via 16 CFR 1250.2(a)
Requirement Cords, Straps, and Elastics · CPSC · pulled in by the cord or string
Accessible cords, straps and elastics on toys for the youngest age bands meet the toy standard's length and performance requirements, and section 4.14 is on the third-party testing list.
“(N) Section 4.14, Cords, Straps, and Elastics”
16 CFR 1112.15(b)(32)(ii), eCFR
“Accessible cords, straps, and elastics found in toys intended for children under 18 months of age in some circumstances and intended for children under 36 months of age in other instances, must meet certain length and/or performance requirements. Examples of such products range from pull toys to kites.”
CPSC, ASTM F963 Requirements chart
Why here. A fact worth knowing before searching the CFR for a cord rule: there is none — the word strangulation appears nowhere in parts 1500, 1501 or 1250. The operative requirement lives in ASTM F963-23 section 4.14, whose number, title and third-party status are fixed by the CFR's own testing list; the numeric limits sit in ASTM's copyrighted text, viewable read-only in its Reading Room. CPSC's summary places the requirements on toys intended for children under 18 months in some circumstances and under 36 months in others.
19 U.S.C. 1304 and 19 CFR part 134
Requirement Country of origin marking · U.S. Customs and Border Protection · pulled in by importing
Every imported article, or its container, is marked legibly, indelibly and permanently, in a conspicuous place, with the English name of the country of origin.
“every article of foreign origin (or its container) imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article … will permit, in such manner as to indicate to an ultimate purchaser in the United States the English name of the country of origin …”
19 CFR 134.11, eCFR
Why here. Commonly filed under the wrong agency. This is Customs, under the Tariff Act — not the FTC, whose rule at 16 CFR part 323 governs claims of United States origin. It is also separate from the tracking label above, even where one stamp carries both.
Cal. Health & Safety Code 25249.6 (Proposition 65)
Requirement Required warning before exposure to chemicals known to cause cancer or reproductive toxicity · California, OEHHA · pulled in by where it is sold
No knowing, intentional exposure to a listed chemical without a clear and reasonable warning first. Lead is listed twice under separate endpoints; DEHP, DBP, BBP, DINP and DIDP are listed too.
“No person in the course of doing business shall knowingly and intentionally expose any individual to a chemical known to the state to cause cancer or reproductive toxicity without first giving clear and reasonable warning …”
Cal. Health & Safety Code 25249.6, California Legislative Information
“the warning is not prominently displayed if the purchaser must search for it in the general content of the website.”
27 CCR 25602(b)(1)(C), OEHHA compilation
Why here. Selling nationwide reaches California buyers, and the safe-harbour figures are a different kind of number from the federal ones. Federal lead limits are concentrations: 90 ppm in a dried film, 100 ppm in a part. California's are daily exposure: 0.5 micrograms a day for lead as a reproductive toxicant, 15 by mouth as a carcinogen. The two do not convert without an exposure assessment, so meeting the federal caps is not a safe harbour here. DEHP's figure is stratified by route and age — the oral level for infant boys from 29 days to 24 months is 58 micrograms a day against 410 for an adult, so where the declared grading lands changes which figure governs. The Attorney General's register shows 2026 notices over lead in paint and phthalates in toys, one naming an online marketplace beside a brand.
22 M.R.S. 1316-A
Requirement Sale of lead-containing children's products (Maine) · Maine · pulled in by the paint
A children's product coated with a paint whose lead content exceeds 16 CFR part 1303 may not be made, sold or distributed in Maine.
““Lead-containing children's product” means a children's product that … (2) Is coated with a paint or surface coating with a lead content that exceeds the Consumer Product Safety Commission safety rule as established in 16 Code of Federal Regulations, Part 1303 …”
22 M.R.S. 1316-A(1)(F), Maine Legislature
Why here. A painted toy sold nationally is sold in Maine. The interest is structural: the state adopts the federal figure by reference, so a coating that satisfies part 1303 satisfies this and no extra laboratory work appears — but two authorities can now act on the same number. It also sits in the Lead Poisoning Control Act, not the toxics chapter.
OAR 333-016-3010(1)
Requirement Removal or substitution of high priority chemicals of concern for children's health (Oregon) · Oregon Health Authority · pulled in by the age grading
By the third biennial notice, a listed chemical in a children's product that is mouthable, a children's cosmetic, or marketed to children under three is removed or substituted, or a waiver sought.
“the manufacturer must remove or make a substitution, or seek a waiver … if the HPCCCH is present in a children's product that is: (a) Mouthable; (b) A children's cosmetic; or (c) Made for, marketed for use by or marketed to children under three years of age.”
OAR 333-016-3010(1), Oregon Secretary of State
Why here. The tier is defined by age and the criteria are alternatives, so an under-3 grading lands in it on the third branch alone. Two particulars matter more than the rule text suggests: worldwide gross sales under five million dollars exempt a maker automatically, and — the opposite of California — Oregon lets compliance with a federal safety standard ground an exemption from the removal duty.
Connecticut Public Act 24-59, sections (b) and (c)
Requirement Notification and labeling of products containing PFAS · Connecticut DEEP · pulled in by where it is sold, if the coating carries PFAS
From 1 July 2026 a children's product containing intentionally added PFAS may not be sold in Connecticut without prior written notification to the department, and without a durable label in wording the department approves.
“All labels shall be clearly visible prior to sale and shall inform the purchaser, using words or symbols approved by the department, that PFAS is present in the product.”
Connecticut Public Act 24-59 section (c)(3)
Why here. The state's definition of a children's product is open-ended, so a toy is not written out of it. What decides the matter is a supplier fact a declaration cannot settle: whether the coating carries intentionally added PFAS. One declaration from the coating maker settles Connecticut and the same question in several other states at once. The approved wording the label depends on is something we could not confirm has been published.
Three more rules are in play and are taken up where they bite rather than here: 16 CFR part 1107 and part 1109 govern the testing in stage 2, and 16 CFR part 1110 is the whole of stage 3.
Rules that do not reach it, and the fact that keeps them out
A map that only lists what applies is half a map. These were checked and left out, each for a stated reason.
- Not reached Lead-containing paint · 16 CFR part 1303
No coating is declared, so the lead-paint ban has nothing to act on. The total-lead cap above still reaches every material part on its own. Primary text
- Not reached Magnets · 16 CFR part 1262
No magnet is present, so the rule has nothing to act on. Independently, 16 CFR 1262.1(c) carries an exclusion for toys. Primary text
- Not reached Durable infant or toddler products · 16 CFR parts 1215 to 1243, via 1130.2(a)
A closed list of twenty categories, from cribs to bed rails. A puzzle or board game is in none of them, so no registration card either. Primary text
- Not reached The choking-hazard warning label · 16 CFR 1500.19(b)(1)
Its own words limit it to children at least three and under six. Below that floor a small part is a ban, and no label turns it into a disclosure. The most consequential exclusion here. Primary text
- Not reached The small-parts ban, and the 3-to-under-6 label · 16 CFR part 1501 and 16 CFR 1500.19(b)(1)
The ban's own scope ends at children under 3, and the small-parts label trigger ends at six — but the edge is narrower than it looks: a small ball or marble is labeled with no upper age bound, a toy containing one is labeled to under eight, and a latex balloon is labeled at any age. The stated age also only counts if it is a reasonable one. Primary text
- Not reached Flammability inside the toy standard · ASTM F963-23 section 4.2 and Annex 5
16 CFR 1250.2(b) writes both out of the mandatory standard; flammability is reached on the hazardous-substances side instead. Primary text
- Not reached Batteries, sound, mechanisms and cords · The F963-23 sections written for those features
None are present, so the toy standard's sections for them are absent above. A fact about the product, not relief from a rule. Primary text
- Not reached Country of origin marking · 19 U.S.C. 1304 and 19 CFR part 134
Nothing is imported, so the Tariff Act marking duty has nothing to act on. The mirror image applies instead: claiming Made in USA is governed by the FTC's rule at 16 CFR part 323 — a claims rule, not a marking mandate. Primary text
2. What testing those rules call for
Three questions get flattened into one and behave differently: does the rule reach the product, does the limit have to be met, and does a CPSC-accepted laboratory have to measure it. 16 CFR 1112.15(b) settles the third, and relief from testing is never relief from the limit.
Chemistry
Lead in the dried paint film, against 90 ppm. CPSC-CH-E1003-09.1, or ASTM F2853-10 by energy-dispersive X-ray.
Third party? Yes, with no way out. 16 CFR 1112.15(b)(10), and part 1303 sits in the statutory Group A that CPSC says small batch registrants are ALWAYS held to.
Total lead in the non-metal substrate, against 100 ppm. CPSC-CH-E1002-08.3.
Third party? No, for the wood: 16 CFR 1500.91(d)(4). The limit itself still stands.
Total lead in the non-metal substrate, against 100 ppm. CPSC-CH-E1002-08.3.
Third party? It depends on the board: part 1252's determinations carry their own conditions, read against the board type. The limit itself still stands.
Total lead in the non-metal substrate, against 100 ppm. CPSC-CH-E1002-08.3.
Third party? No determination is read on this page for the declared materials, so the substrate is measured — whether any determination reaches die-cut paperboard is not established from the texts read here. The limit is the same 100 ppm.
The eight restricted phthalates, against 0.1 percent each. CPSC-CH-C1001-09.4, or GB/T 22048-2008.
Third party? Yes for the coating and any adhesive. No for untreated, unfinished wood, under 76 FR 49286 footnote 2 and the component-part policy.
The eight restricted phthalates, against 0.1 percent each. CPSC-CH-C1001-09.4, or GB/T 22048-2008.
Third party? Yes for plasticized pieces, printed coatings and adhesives, measured against component parts. No general relief is read on this page for the declared materials.
The eight soluble heavy elements, by ASTM F963-23 sections 8.3.2 for surface coatings and 8.3.5 for substrates. No CPSC method number exists for these.
Third party? Yes for the coating, under 16 CFR 1112.15(b)(32)(ii). For the wood it depends on paint: 16 CFR 1251.2 shelters only surfaces with no coating on them.
The eight soluble heavy elements, by ASTM F963-23 sections 8.3.2 for surface coatings and 8.3.5 for substrates. No CPSC method number exists for these.
Third party? Yes for the surface coatings, under 16 CFR 1112.15(b)(32)(ii). 16 CFR 1251.2's determination is written for unfinished and untreated wood and is not read against the declared materials.
Physical and mechanical
Small parts: the cylinder, then the use and abuse conditioning of 16 CFR 1500.51 and 1500.52 with the bite tests left out, then the cylinder again on anything that came off — a glued knob or a pawn on a stand is judged after conditioning, not just as boxed.
Third party? Yes, with no way out — Group A again, at 16 CFR 1112.15(b)(14). A finished-article test, so no component report stands in for it.
Small parts at 3-to-under-6: the same cylinder decides, but on the article as sold — 16 CFR 1500.19(a)(5) reads the use-and-abuse conditioning out of the label's small-part definition — and what it decides is the 16 CFR 1500.19(b)(1) label, not a ban.
Third party? No — 16 CFR 1112.15(b) carries no line for the labeling rule, and CPSC states certificates need not cite it. The duty is wording on the package, checked by eye against the regulation's own table.
Accessible edges (F963-23 section 4.7), projections (4.8), accessible points (4.9), stability and overload (4.15) and holes and clearances (4.18). On a die-cut board or a metal tin, edges is the section doing the work.
Third party? Yes to all five, at 16 CFR 1112.15(b)(32)(ii)(G), (H), (I), (O) and (R).
Folding mechanisms and hinges — F963-23 section 4.13, where the build has a folding board, a folding leg or a hinged box.
Third party? Yes — 16 CFR 1112.15(b)(32)(ii)(M), where that hardware exists.
Battery accessibility and related battery requirements — F963-23 section 4.25.
Third party? Yes — 16 CFR 1112.15(b)(32)(ii)(Z). And the exemption from part 1263 holds only while these are met; part 1263 carries its own line at 1112.15(b)(55).
Magnets — F963-23 section 4.38, flux index against the small-parts cylinder.
Third party? Yes — 16 CFR 1112.15(b)(32)(ii)(HH).
Battery-operated toys and sound — F963-23 sections 4.25 and 4.5.
Third party? Yes to both — 16 CFR 1112.15(b)(32)(ii)(Z) and (E).
Cords, straps and elastics — F963-23 section 4.14.
Third party? Yes — 16 CFR 1112.15(b)(32)(ii)(N).
Material quality — F963-23 section 4.1.
Third party? No. CPSC treats sections judged by the unaided eye as outside third party testing.
Burn rate as a flammable solid — 16 CFR 1500.44.
Third party? No: 16 CFR 1112.15(b) carries no line for it, so no accredited scope exists. The prohibition is still live.
Tracking label, and country of origin marking.
Third party? No to both. CPSC states the tracking label is not assessed by a third party laboratory; origin marking is Customs' and not a laboratory matter.
16 CFR 1112.15, the list that settles third party testingCPSC: rules requiring third party testing
How often the testing comes back
16 CFR 1107.21 sets three maximum intervals for periodic third party testing: at most yearly, at most every two years with a written production testing plan, or at most every three with continued testing at an ISO/IEC 17025-accredited laboratory. Which is available is not decided by the rule alone. Amazon states that a US toy listing wants a report issued within the past twelve months — inside all three options, but for anyone selling there it fixes the cycle at a year. That annual cost is set by the channel, not the regulation.
How often the testing comes back
16 CFR 1107.21 sets three maximum intervals for periodic third party testing: at most yearly, at most every two years with a written production testing plan, or at most every three with continued testing at an ISO/IEC 17025-accredited laboratory. Which is available is not decided by the rule alone — a marketplace's own document expectations can fix the cycle in practice, so the channel's current policy pages are part of the answer.
What the testing costs
No regulation prices a test. Published laboratory price indications collected for this project in August 2026 put third-party toy-standard testing at roughly $400 to $1,600 per product, with base quotes observed from about $420 and totals rising with materials, added features such as batteries or magnets, and the number of applicable standards. These are observed market figures from the sources linked here — not a quote for any product. The two-half quotation pattern in the last stage is how a real number gets found.
JJR Lab on ASTM F963-23 testing costCompliance Gate on CPSIA lab testingEurofins ASTM F963 testing FAQ
The eight soluble elements, and how firm the figures are
| Element | Soluble limit (ppm) |
|---|---|
| Antimony | 60 |
| Arsenic | 25 |
| Barium | 1000 |
| Cadmium | 75 |
| Chromium | 60 |
| Lead | 90 |
| Mercury | 60 |
| Selenium | 500 |
Transcribed from two CPSC primary documents: the preamble to the 2018 determinations rule at 83 FR 28991, and a 2012 CPSC staff report on metals in the toy standard. Both predate ASTM F963-23, a purchased document we have not read, so we cannot confirm from primary material that the 2023 revision left them unchanged.
How long it takes
No number here. No rule sets a laboratory turnaround, CPSC publishes none, and the price lists we could reach state no standard days; the timing comes out of the quotations. Two timings are fixed and primary-sourced: a certificate is produced within 24 hours of a request from CPSC or Customs, and CPSC estimates the filing at entry at 15.3 seconds per reference message set and 4.75 minutes per full one.
3. What the certificate has to say, and who signs it
One document carries all of the above into a shipment. Its contents changed on 8 July 2026, and the version below is the current one at 16 CFR 1110.11(a), read from the regulation rather than an explainer.
Who issues it
For goods made outside the United States the rule names the importer of record as the certifier. Not the factory. A certificate the factory holds is no substitute: the certifier stays legally answerable for what is on it and needs the underlying test records. CPSC also states the certificate is not applied for or registered — it is written.
“Except as otherwise provided in a specific rule, ban, standard, or regulation enforced by CPSC, for a finished product manufactured outside of the United States that must be accompanied by a certificate as set forth in § 1110.5, the importer, as defined in this part, is the finished product certifier that must issue a finished product certificate that meets the requirements of this part.”
16 CFR 1110.7(a), eCFR
Who issues it
For goods manufactured in the United States the rule names the manufacturer as the certifier — 16 CFR 1110.7 identifies the importer for goods made overseas, and the manufacturer for goods made domestically. The duty does not move to a retailer or a marketplace, and CPSC states the certificate is not applied for or registered — it is written.
The seven contents at 16 CFR 1110.11(a)
- Identifies the finished products covered, carrying at least one unique identifier — a GTIN, model number, registered number, serial number, SKU, UPC or alternate identifier — with enough description to match the product to the certificate.
- States each consumer product safety rule, ban, standard or regulation the products are being certified to, identifying all of them separately.
- Identifies the finished product certifier, as set out in 16 CFR 1110.7, with that party's name, street address, city, state or province, country, email address and telephone number.
- Identifies the individual who maintains the records listed in 16 CFR 1110.17, with the same contact details. A position title is allowed provided the post is always staffed.
- Gives the date and place the products were manufactured, produced or assembled, down to a manufacturer name, address, email and telephone number.
- Gives the most recent date and places of testing, including the name and contact details of each third party conformity assessment body the certificate depends on.
- Carries the finished product certifier's attestation. eFiled attestations sit in the Product Registry and in CBP's message set; paper and electronic certificates carry the wording the rule sets out.
The seventh item is where older lists go wrong. Before 8 July 2026 it was the identification of the third party laboratory; that is now folded into the sixth, and the seventh is the certifier's sworn attestation, whose wording the regulation sets out in full. A list with a laboratory in seventh place is describing the superseded version.
The attestation the rule prescribes, in full:
“I hereby certify that the finished product(s) covered by this certificate comply with the rules, bans, standards, and regulations stated herein, and that the information in this certificate is true and accurate to the best of my knowledge, information, and belief. I understand and acknowledge that it is a United States federal crime to knowingly and willfully make any materially false, fictitious, or fraudulent statement, representation, or omission on this certificate.”
16 CFR 1110.11(a)(7), eCFR
How a determination gets written down
Relief from testing is not something to leave off. Where an exclusion is claimed the rule still wants every applicable rule listed under item two, and asks for the exclusion to be identified in place of the test date and place under item six.
“if a finished product certifier is claiming a statutory or regulatory testing exclusion to an applicable consumer product safety rule … then in addition to listing all applicable rules, bans, standards, and regulations as required under § 1110.11(a)(2), and in lieu of providing the date and place where testing was conducted for that regulation under § 1110.11(a)(6), a finished product certificate shall identify the applicable testing exclusion.”
16 CFR 1110.11(c), eCFR
What happens to it afterwards
- At import
eFiled in Customs' ACE at the time the entry is filed. 16 CFR 1110.13(a)(1).
- To a marketplace or retailer
Furnished to each distributor and each retailer. 16 CFR 1110.13(b).
- Selling direct
Nobody to furnish it to, and the 24-hour production duty is unchanged. 16 CFR 1110.13(c).
- Per item
Each certificate describes only one product.
- Keeping it
Five years from the creation date. 16 CFR 1110.17.
eFiling, in effect since 8 July 2026
Two routes. Under the full message set the broker files seven data elements at entry. Under the reference message set the certificate goes into CPSC's Product Registry first and the broker files three identifiers pointing at it; CPSC expects over 96 percent of importers to take that route. The Registry is free, and its trap is that it does not talk to ACE: a certificate sitting in it does nothing at the border until the identifiers reach the broker. Test reports are not filed. Foreign trade zone goods come in on 8 January 2027.
An entry without the data can still clear today, and CPSC says it does not currently intend to ask Customs to refuse entry on that ground alone. It says in the same breath that it continues to enforce certificate requirements and to ask Customs to seize goods that do not meet them.
Two points we could not settle
- Whether the flammable-solid prohibition belongs among the citations under item two. Item two is worded widely enough to take in any ban the Commission enforces; but the CPSC lists that guide what to cite are lists of rules needing third party testing, and it is not on them.
- How the phthalate relief for solid wood is written under item six. The other determinations have a CFR paragraph to name; this one lives in a notice and a policy statement, and we found no CPSC example.
- One drafting oddity, quoted as published: item six refers to the rules “cited in § 1110.11(a)(4)”, and the paragraph that enumerates rules is (a)(2). We found no correction notice, and have not corrected the text.
4. What you have declared about where things stand
Every line here is your own answer, repeated back. Nothing was inspected, inferred or scored to produce it.
- Answered
Certificates are already held for all products. Stage 3 is then a comparison exercise: the held documents against 16 CFR 1110.11(a) as amended on 8 July 2026 — older lists put the laboratory seventh; the current text folds it into the sixth item and ends at the attestation.
- Answered
Some products have certificates and others do not. Each certificate describes only one product, so the covered and uncovered lists run through this page separately.
- Answered
No certificate has been issued yet.
- Answered
Whether a certificate exists is not known. Finding out is a document question, not a laboratory one.
- Not answered
Whether any certificate exists.
- Answered
Third-party test reports are held in your own name.
- Answered
Test reports exist under another buyer's name, or sit with the factory. The name is where this bites: 16 CFR 1110.7 names the importer as the certifier for goods made overseas, and the certifier needs the underlying records — a report the factory holds is an input, not the answer.
- Answered
No test reports are held.
- Answered
Whether test reports exist — from the factory, a previous buyer, or the coating maker — is not known.
- Not answered
Whether any test report exists — from the factory, a previous buyer, or the coating maker.
- Answered
Permanent marks are on the product and on the packaging.
- Answered
Permanent marks are on one of product and packaging, but not both — the statute asks for both, to the extent practicable.
- Answered
What permanent marks are on the toy and the box today is not established.
- Not answered
What permanent marks are on the toy and the box today.
5. What that leaves open
This is stage 4 subtracted from stages 1 to 3 — arithmetic on answers given, not a measurement of any object. Each line names the rule it came from.
- The artwork is not settled
Whether and where the surface is coated is undeclared, and it decides the lead-paint row and the whole coating bill above. Free to decide now, expensive after tooling. 16 CFR 1303.
- The piece inventory is not identified in the declared facts
Which pieces fit the small-parts cylinder, and whether a ball, marble, balloon or die is among them, is not declared — and those facts decide ban against label against neither row at all. This is declaration arithmetic, not a measurement of any object. 16 CFR 1501.4, 1500.18(a)(17), 1500.19.
- No certificate is established
So there is nothing to eFile at entry, nothing to furnish to a marketplace or retailer, and nothing to produce within 24 hours. 16 CFR 1110.5, 1110.13.
- Part of the range has no certificate
For the uncovered products there is nothing to eFile, furnish or produce; each certificate describes only one product. 16 CFR 1110.5, 1110.13.
- The coating is not identified in the declared facts
Without a maker, a part number and a data sheet the coating tests cannot be scoped, no existing report can be relied on, and there is no baseline against which a later substitution would count as a material change. 16 CFR 1303, 1109.5, 1107.23(d).
- No test reports are established
The two that cannot be avoided are lead in the coating and small parts. 16 CFR 1112.15(b)(10) and (b)(14).
- No test reports are established
Which rows above carry a third-party line sets the minimum: on a bare build the coating rows fall away, and the finished-article mechanical work remains. 16 CFR 1112.15(b).
- The reports' name does not match the certifier
A certificate needs the underlying test records behind the certifier named on it. Whether reports issued under another buyer's name can be relied on runs through 16 CFR 1109's conditions — a question to settle in writing before anything is retested needlessly. 16 CFR 1109.5, 1110.7.
- No laboratory is chosen
Being CPSC-accepted is not enough: 16 CFR 1112.15(a) limits a laboratory to results inside its accepted scopes.
- Marking is not established
Two marks, two authorities: the tracking label under 15 U.S.C. 2063(a)(5)(A), and the English origin marking under 19 U.S.C. 1304.
- California is undecided
Whether to warn on the label or notify each channel's authorised agent in writing, and either way to warn before checkout. 27 CCR 25600.2, 25602(b).
- The PFAS question is unanswered
One declaration from the coating maker closes Connecticut's duties and the same question in the other open-definition states, or opens them.
- Oregon is unresolved
The under-three removal tier applies on its face; whether it matters turns on worldwide sales against the five million dollar exemption.
What would close these for you
Everything shown above this line is reading published rules against stated facts, which is what the free scan does.
Planned MooseClear is being built to take a real specification, settle the rows above into a fixed list for one item, put it into the shape a laboratory quotes against, and assemble the certificate from the documents that come back. That part is not built yet, and is marked as such. The plans below are shown so we can measure genuine purchase intent — no charge is taken during this validation.
Early-access workflow
No charge during validationNo charge is taken during this validation. Pricing is shown so we can measure genuine purchase intent.
Starter
- Guided setup for a small catalog
- Structured checklists for CPC and eFiling readiness
- Email support during early access
Growth
- Ongoing workflow across your product line
- Readiness tracking as requirements change
- Priority support during early access
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Used only to contact you about the pilot — nothing else. Leave it blank and your request still stands.
6. What closes each of those, in order
Each action answers one line of stage 5, in the order the dependencies fall: the drawing decides the testing, the testing decides the certificate, the certificate decides the entry.
- Settle the drawing first
Decide which faces are coated and which stay bare, whether the wood is solid or engineered, and whether dowels are glued. Those answers decide whether 16 CFR 1251.2 can be claimed for any part, whether part 1252 comes into it, and whether an adhesive joins the phthalate scope. Free now, expensive after tooling.
- Ask the factory, in writing
The questions further down this page are the standing set. For a coated wooden item, add the coating's maker, part number and data sheet, whether the coating maker holds reports usable under 16 CFR 1109.5, and a written statement on intentionally added PFAS.
- Pick a laboratory by scope, not by name
Check the scopes rather than the acceptance: a laboratory without the part 1303 scope cannot produce a lead-in-paint result that counts.
- Ask for the quotation in two halves
Coating chemistry is quoted once and reused across items under 16 CFR 1109.11(b); small-parts and mechanical work is quoted per item. Put the age-band question from stage 2 in the same message.
- Write the certificate against the regulation
Draft it from 16 CFR 1110.11(a) itself, attestation included, and use 1110.11(c) wherever a determination stands in for a test. Explainer pages, including CPSC's own, can carry a superseded element list.
- Set up filing before the shipment
Open a Product Registry account, enter the certificate, take the three identifiers and get them to the customs broker. The Registry passes nothing to ACE by itself.
- Deal with California separately
Choose between a label warning and written notice to each channel's authorised agent, get the acknowledgement in writing, and diarise the annual renewal. The federal concentration limits do not answer this.
- Then keep it true
Choose a periodic testing route under 16 CFR 1107.21 with the channel's twelve-month expectation in mind, hold the coating to a named part number, keep records five years, and treat later news of a failure as starting the clock under 15 U.S.C. 2064(b), which reaches an importer as a manufacturer.
Every rule and test here was read from the primary text — eCFR at the 1 August 2026 snapshot, the United States Code, the Federal Register, cpsc.gov, and the state sources linked beside each row. Questions that could not be settled from primary material are marked unsettled rather than filled in. Rows shown for declared features — batteries, magnets, electronics, cords — were read from the CFR sections and Federal Register documents linked beside each row, retrieved in August 2026.