Your map: a ride-on or outdoor toy 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 ride-on or outdoor toy. 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.
No declared facts were found from a scan in this browser session. Declare them below — each answer stays in this browser — or run the free scan first.
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 1512, with 16 CFR 1500.18(a)(12)
Requirement Requirements for Bicycles — the boundary that decides this category · CPSC · pulled in by pedals and two wheels, if the product has them
A ride-on with pedals and two wheels answers to part 1512, not the toy standard: a two-wheeled vehicle with a rear drive wheel that is solely human-powered is a bicycle, and one whose maximum seat height is 635 mm (25.0 in) or less is a sidewalk bicycle — still a part 1512 bicycle, with certain exemptions and alternatives inside the part. A bicycle that does not comply with part 1512 is a banned article under 16 CFR 1500.18(a)(12); a children's bicycle is third-party tested to part 1512 under 16 CFR 1112.15(b)(18), and its certificate cites part 1512, not part 1250.
“(a) Bicycle means: (1) A two-wheeled vehicle having a rear drive wheel that is solely human-powered; (2) A two- or three-wheeled vehicle with fully operable pedals and an electric motor of less than 750 watts (1 h.p.), whose maximum speed on a paved level surface, when powered solely by such a motor while ridden by an operator who weighs 170 pounds, is less than 20 mph.”
16 CFR 1512.2(a), eCFR
“(b) Sidewalk bicycle means a bicycle with a seat height of no more than 635 mm (25.0 in); the seat height is measured with the seat adjusted to its highest position. Recumbent bicycles are not included in this definition.”
16 CFR 1512.2(b), eCFR
“(12) Any bicycle as defined in § 1512.2(a) of this chapter (except a bicycle that is a "track bicycle" or a "one-of-a-kind bicycle" as defined in § 1512.2 (d) and (e) of this chapter) that is introduced into interstate commerce on or after May 11, 1976, and that does not comply with the requirements of part 1512 of this chapter, except for §§ 1512.5(c)(3), 1512.9(a), 1512.18(e) and 1512.18(f) which become effective November 13, 1976.”
16 CFR 1500.18(a)(12), eCFR
“(18) 16 CFR part 1512, Requirements for Bicycles;”
16 CFR 1112.15(b)(18), eCFR
“A "toy" is defined as any object designed, manufactured, or marketed as a plaything for children under 14 years of age but does not include: Bicycles; Tricycles; Non-powered scooters as defined in ASTM F2264; Recreational powered scooters and pocket bikes as defined in ASTM F2641; Sling shots and sharp-pointed darts; Playground equipment; Non-powder guns; Kites; …”
CPSC, Toy Safety Business Guidance
Why here. Bicycles are written out of the toy definition CPSC applies for the toy standard, which is what routes a first pedal bike at 12 or 16 inches away from every F963 row on this page: if the product is a part 1512 bicycle, none of the toy-standard test rows in stage 2 apply to it, and the sidewalk-bicycle provisions inside 1512 take over — down to the no-brakes label alternative at 1512.5(e) and 1512.18(f) for the smallest bikes. A pedal e-bike under 750 watts and 20 mph is also a 1512 bicycle, on the definition's second branch. Two honest edges: part 1512 contains no certification subpart of its own — the children's certificate flows from the general CPSA section 14 framework — and a non-powered balance bike's place is a definitional inference, not a quoted holding: with no rear drive wheel it falls outside the 1512.2(a)(1) text, and a CPSC staff report says the same of electric balance bikes, but no Commission rule states it for the non-powered kind.
CPSC toy-definition exclusions, with ASTM F2264 and F2641 (voluntary)
Requirement Kick scooters and powered recreational scooters sit outside the toy standard · CPSC · pulled in by the scooter question
A non-powered scooter as defined in ASTM F2264, and a recreational powered scooter or pocket bike as defined in ASTM F2641, are written out of the toy definition CPSC applies for the toy standard — no product-specific mandatory federal standard reaches them, and F2264 and F2641 are voluntary. The children's-product basics — total lead, the lead-paint ban, the tracking label, the certificate — still reach one primarily intended for children 12 or younger.
“A "toy" is defined as any object designed, manufactured, or marketed as a plaything for children under 14 years of age but does not include: Bicycles; Tricycles; Non-powered scooters as defined in ASTM F2264; Recreational powered scooters and pocket bikes as defined in ASTM F2641; Sling shots and sharp-pointed darts; Playground equipment; Non-powder guns; Kites; …”
CPSC, Toy Safety Business Guidance
Why here. The exclusion list is CPSC's own, and the gap reads both ways: nothing product-specific is mandatory, and nothing in that sentence relieves the children's-product layer. One edge stays open in the primary text: whether the phthalates rule reaches a scooter is not directly stated — CPSC's parallel reasoning for non-toy playground equipment is that such a product may not be a part 1250 toy but “may still be subject to the phthalate requirement”, a hedge CPSC has not resolved and this page does not resolve either. Tricycles sit on the same exclusion list with no standard cross-reference at all, while CPSC's own section 4.15 guidance says ride-on toys are covered by the toy standard — where an excluded tricycle ends and a covered ride-on toy begins is not settled by any primary source we found.
16 CFR part 1420, via 16 CFR 1112.15(b)(11)
Requirement Ride-ons that meet the ATV definition leave the toy standard · CPSC · pulled in by size and power, if they reach the ATV definition
A ride-on that meets the statutory definition of an all-terrain vehicle answers to the ATV standard at 16 CFR part 1420 instead of the toy standard, with its own third-party line at 16 CFR 1112.15(b)(11).
“Certain "ride-on toys" may meet the statutory definition of an all-terrain vehicle (ATV). Such products would be subject to 16 C.F.R. part 1420 instead of ASTM F963.”
CPSC, Toy Safety Business Guidance (section 4.15 note)
“(11) 16 CFR part 1420, Safety Standard for All-Terrain Vehicles;”
16 CFR 1112.15(b)(11), eCFR
Why here. The carve-out is CPSC's own, written into its toy-standard guidance for section 4.15. It matters at the large end of this category — quads with real motors marketed to children — and the statutory definition, not the marketing, decides which side of the line a product lands on.
CPSA section 15(a), 15 U.S.C. 2064(a) — and proposed 16 CFR part 1265 (91 FR 38162)
Requirement Hoverboards and kids' e-scooters: no toy standard, a compliance letter, and a proposed rule · CPSC · pulled in by the self-balancing or powered-scooter question
No mandatory federal standard reaches a self-balancing scooter today. CPSC's compliance letter of December 19, 2022 urges conformance with UL 2272 and UL 2849 and states that products not meeting those standards could present a substantial product hazard under CPSA section 15(a). A lithium-battery rule for micromobility products was proposed on June 24, 2026 as 16 CFR part 1265 — proposed, not final, with written comments due August 24, 2026.
“I am writing to urge you to ensure that the micromobility devices for consumer use that you manufacture, import, distribute, or sell in the United States have been designed, manufactured, and certified for compliance with the applicable consensus safety standards. These safety standards include ANSI/CAN/UL 2272 – Standard for Electrical Systems for Personal E-Mobility Devices dated February 26, 2019, and ANSI/CAN/UL 2849 – Standard for Safety for Electrical Systems for eBikes dated June 17, 2022 … Accordingly, products that do not meet these standards could present a substantial product hazard under Section 15(a) of the CPSA, 15 U.S.C. § 2064(a)”
CPSC compliance letter, December 19, 2022 (Office of Compliance and Field Operations)
“Lithium battery-powered motive products that are not micromobility products are excluded from the scope of this proposed rule including children's battery-powered ride-on toys (defined in 16 CFR part 1250), ATVs (defined in 16 CFR part 1420), Recreational Off-Highway Vehicles (defined in ANSI/ROHVA 1-2023), Multipurpose Off-Highway Utility Vehicles (defined in ANSI/OPEI B71.9-2022), and Golf Cars (defined in ANSI/ILTVA Z130.1).”
91 FR 38162 (June 24, 2026), preamble footnote 5, Federal Register
Why here. Stated as it stands: a compliance letter is enforcement posture, not a standard, and a proposal is not a rule. The proposal's own footnote is the discriminating fact for this category — children's battery-powered ride-on toys under part 1250 are expressly excluded from its scope — so a 6- or 12-volt ride-on car reads its battery duties from the toy standard's section 4.25, not from the micromobility docket. If the proposal is finalised, the NPRM also proposes adding the rule to the third-party testing list for the children's micromobility products it does cover; until then, nothing in it binds anyone.
16 CFR part 1250
Requirement Safety Standard for Toys (ASTM F963-23) · CPSC · pulled in by being a toy ride-on
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 reaches the ride-ons that ARE toys — the foot-to-floor car, the rocking ride-on, the battery ride-on — and not the ones the definition writes out: a pedal bicycle answers to part 1512, an ATV-defined vehicle to part 1420, and a kick scooter or recreational powered scooter to no toy standard at all. 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.
ASTM F963-23 sections 4.15, 4.17 and 4.39, via 16 CFR 1250.2(a)
Requirement Stability, wheels and steering — the toy standard's ride-on sections · CPSC · pulled in by being ridden
A ride-on toy meets the toy standard's stability and overload section (4.15), its wheels, tires and axles section (4.17), and its jaw-entrapment section for handles and steering wheels (4.39) — all three on the third-party testing list. The battery section, 4.25, rides in with the declared battery feature below.
“(O) Section 4.15, Stability and Overload Requirements”
16 CFR 1112.15(b)(32)(ii), eCFR
“(Q) Section 4.17, Wheels, Tires, and Axles”
16 CFR 1112.15(b)(32)(ii), eCFR
“(II) Section 4.39, Jaw Entrapment in Handles and Steering Wheels”
16 CFR 1112.15(b)(32)(ii), eCFR
“Toys with wheels, tires, and axels must not pose a laceration, puncture, or ingestion hazard before and after use-and-abuse testing.”
CPSC, Toy Safety Business Guidance (section 4.17 note)
Why here. The section numbers and their third-party status are fixed by the CFR's own list; the content sits in ASTM's copyrighted text, so only the titles and CPSC's plain-language summaries are quotable. CPSC's summary ties 4.15 to ride-ons directly — stability whether the toy stands on its own or is assisted by the rider, and no collapse under the overload test. One correction worth writing down, because secondary write-ups repeat the mistake: section 4.28 is Stroller and Carriage Toys — toys attached to strollers and carriages, not ride-on projections — and it is not on the third-party list. Projections is section 4.8, which sits with the general mechanical rows in stage 2.
16 CFR 1112.15(b) — no playground entry (verified negative)
Requirement Playground equipment: no mandatory federal standard, and the basics that remain · CPSC · pulled in by the outdoor play equipment question
No mandatory federal standard is written for home or public playground equipment, and no playground entry exists in 16 CFR 1112.15(b). ASTM F1148 and F1487 are voluntary, and CPSC's playground handbooks are staff recommendations. What remains is the children's-product layer — total lead, the tracking label, the certificate, small parts by age — when the equipment is primarily intended for children 12 or younger, and the toy standard for any toy accessories attached to it.
“Home playground equipment meant for indoor use, such as a small slide, may be considered a children's toy that would need to meet the applicable requirements for children's toys (such as the toy standard per 16 C.F.R. part 1250, or the phthalate requirement per 16 C.F.R. part 1307).”
CPSC, Playground Equipment Business Guidance
“Home playground equipment meant for outdoor use only, on the other hand, may not be considered a toy per 16 C.F.R. part 1250 but may still be subject to the phthalate requirement. There are no specific statutory requirements for home playground equipment meant for outdoor use only; however, such products likely would need to meet the applicable requirements for children's products if it is primarily designed or intended for children 12 years of age or younger.”
CPSC, Playground Equipment Business Guidance
“There is no specific certification requirement for playground equipment, but products considered children's products or children's toys would require a CPC.”
CPSC, Playground Equipment Business Guidance
Why here. CPSC's own guidance draws the seam finer than the exclusion list suggests: an indoor slide may be a children's toy answering to part 1250 and part 1307, outdoor-only equipment may not be a part 1250 toy but “may still be subject to the phthalate requirement” — CPSC's hedge, not ours, and no primary source retrieved resolves it — and a toy periscope or sliding puzzle bolted to a wall brings part 1250 with it. The negative was verified against the current third-party list, not assumed.
16 CFR part 1303
Requirement Ban of Lead-Containing Paint and Certain Consumer Products Bearing Lead-Containing Paint · CPSC · pulled in by the coating
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 — a paint on a metal frame or a lacquer on a wooden seat does, while a colour moulded through the plastic itself is not a surface coating and answers to the total-lead cap instead. 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 paint on a frame does, a colour moulded through the plastic does not; only the build record says which this product has.
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: frame, body, 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: a metal handlebar, a plastic body, a coating and a label are each measured on their own, and a thin coating cannot be diluted into the weight of the part 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: frame, body, 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: frame, body, 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 drawing 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 parts
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. On a build declared as solid wood that takes the wooden substrate out of the lead bill entirely — and leaves in what is painted on top of it, and any part that is not wood.
16 CFR part 1307
Requirement Prohibition of Children's Toys and Child Care Articles Containing Specified Phthalates · CPSC · pulled in by the plasticized parts, the coating and any adhesive
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, and this category is where the rule's centre of gravity lies: paragraph (c) reaches any plasticized component part, and a soft seat, a grip sleeve or a tire is exactly that — with the coating and any adhesive alongside. Each component part is measured on its own.
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 1251.2
Relief Toys: Determinations Regarding Heavy Elements Limits for Certain Materials · CPSC · pulled in by the bare wood faces
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 determination is written for unfinished and untreated wood — no added surface coatings, with varnish and paint named — and it excludes manufactured or engineered woods. On a build declared as solid wood with bare faces, the relief attaches to those faces only; every coated face, and every part that is not wood, stays in the laboratory's scope for the toy standard's heavy elements. Which faces get coated is decided on the drawing.
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 determination spells out no added surface coatings and names varnish and paint. On solid wood coated on every face nothing answers to the definition, so this relief does not attach while the lead determination above still does. 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 unfinished 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 determination is written for unfinished and untreated wood harvested from the trunks of trees, and its own text excludes manufactured or engineered woods. On the declared materials nothing answers to that definition, so the relief does not attach: plastic and metal substrates stay in the toy standard's heavy-elements scope where accessible, along with any coating.
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.
“This regulation … applies to all toys and other articles intended for use by children under 3 years (36 months) of age … Such articles include, but are not to limited to: … pull and push toys; pounding toys; blocks and stacking sets; …”
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 of what it covers names pull and push toys outright. A detached knob, hubcap or valve cap is judged in the same cylinder as anything else — the fragments excused are paper, fabric, yarn, fuzz, elastic and string, and none of those is what comes off a ride-on.
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.
“This regulation … applies to all toys and other articles intended for use by children under 3 years (36 months) of age … Such articles include, but are not to limited to: … pull and push toys; pounding toys; blocks and stacking sets; …”
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 toy is marketed in a way commonly recognised as for under-3s — this ban reaches it. The rule's own 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 for ages 3 to under 6) · CPSC · pulled in by the age grading
A toy 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 the answer becomes required wording on the box rather than a ban. The statement, its triangle, and the type sizes are set out in the regulation as a published table — not a design choice.
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 ride-on 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 ride-on toy is in none of them, so no registration card — but the neighbourhood is close: an infant swing has its own standard on that list at 16 CFR part 1223, so what the product is decides the answer, not what aisle it sells in. Primary text
- Not reached Bicycle helmets · 16 CFR part 1203, via 16 CFR 1112.15(b)(1)
Part 1203 reaches the helmet, not the ride-on: its definition is headgear marketed, or implied through marketing, as protection while riding a bicycle, with its own third-party line at 16 CFR 1112.15(b)(1) and its own certificates subpart at 1203.30. If a bundle includes a real helmet, the helmet is its own certified product, read against part 1203 separately. A pretend toy helmet is different again: F963-23 section 4.19, Simulated Protective Devices, on the third-party list at 1112.15(b)(32)(ii)(S). No CFR provision imposes helmet requirements on the ride-on product itself. 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, and any non-wood part is measured.
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, part by part, against 100 ppm: plastic bodies and other non-metal parts by CPSC-CH-E1002-08.3, and any metal frame or fastener measured as a metal part against the same cap.
Third party? Yes — no material determination covers a plastic or metal substrate, so each accessible part is measured. The cap 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, any adhesive and any plasticized part. 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 — measured against component parts, and a plasticized seat, grip or tire is squarely what the rule reaches, with the coating and any adhesive alongside.
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 coating, under 16 CFR 1112.15(b)(32)(ii). 16 CFR 1251.2 is written for unfinished and untreated wood only, so it offers nothing on a plastic or metal build.
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.
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 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) and holes and clearances (4.18).
Third party? Yes to all four, at 16 CFR 1112.15(b)(32)(ii)(G), (H), (I) and (R).
Stability and overload — F963-23 section 4.15: a ride-on stands, or holds with the rider's assistance, and does not collapse under the overload test.
Third party? Yes — 16 CFR 1112.15(b)(32)(ii)(O): “Section 4.15, Stability and Overload Requirements”.
Wheels, tires and axles — F963-23 section 4.17, judged before and after use-and-abuse testing.
Third party? Yes — 16 CFR 1112.15(b)(32)(ii)(Q): “Section 4.17, Wheels, Tires, and Axles”.
Steering and handle openings — F963-23 section 4.39.
Third party? Yes — 16 CFR 1112.15(b)(32)(ii)(II): “Section 4.39, Jaw Entrapment in Handles and Steering Wheels”.
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). CPSC's summary of section 4.25 notes requirements for chargers that may be supplied with such toys — which is where a 6- or 12-volt ride-on's charger is read.
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.
- Which instrument governs is not settled by the declared facts
A pedal two-wheeler answers to part 1512, a toy ride-on to part 1250, a kick scooter to neither — and no declared fact above distinguishes them. That classification decides every row on this page before any laboratory enters, so it is the first fact to fix, against the definitions themselves. 16 CFR 1512.2, 1250.2.
- The drawing is not settled
Whether and where the surface is coated is undeclared, and it decides the lead-in-paint row and the whole coating bill. Free to decide now, expensive after tooling. 16 CFR 1303.
- 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
Which rows above carry a third-party line sets the minimum: the finished-article mechanical work — stability, wheels, steering — cannot ride on component reports, and a declared coating adds the lead-in-paint row. 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.