Sample scan: a wooden-toy importer
Synthetic example — not your product, and not anybody's. Invented product. Every fact below was made up so the report can be shown finished end to end. It describes no real company and no real goods, and nothing here is a finding about anyone's product.
One invented product carried the whole way: which published rules reach it, what testing they call for, what the certificate has to say, where this example stands, what that leaves open, and what closes each of those. It is a wooden-toy importer selling on Amazon with no certificates yet, and every rule and test below links its own primary text.
The invented product this report is written about
These eight facts are the whole input, and they are declared rather than observed. Everything after them is read off published rules, and each line says which fact pulled it in.
- What it is
A wooden stacking toy: turned rings and blocks on a post.
- Age grading
18 months to 3 years, printed on the toy and on the box.
- Surface
Painted on every face.
- Magnets
None.
- Batteries
None, and no sound, no mechanism and no cord.
- Where it is made
An OEM factory in China.
- Where it is sold
Amazon, and the importer's own online store.
- Certificates in hand
None yet.
Potential compliance areas to confirm
- Confirm Product classification
Settled above only because the age grading and the coating were stated. A listing shows neither.
- Confirm Existing test and certificate evidence
Which reports and certificates exist is the importer's to confirm.
- Confirm CPSC eFiling readiness
Whether certificate data can be filed at entry, before a shipment.
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 paint. 16 CFR 1303.2(b)(1) draws the boundary around a material that turns into a solid film on wood, which a lacquer or varnish 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.
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. 18 months to 3 years sits inside “12 years of age or younger”. Part-by-part is what matters on a painted item: a thin coating cannot be diluted into the weight of the block under it.
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 1307
Requirement Prohibition of Children's Toys and Child Care Articles Containing Specified Phthalates · CPSC · pulled in by the paint 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. Paragraph (c) reaches any component part made of other materials that may contain phthalates, which is how a coating and a glue line come into scope on a product with no plastic in it.
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: painted, stackable, pierced, with edges and points in wood. 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 the row below.
16 CFR 1251.2
Relief Toys: Determinations Regarding Heavy Elements Limits for Certain Materials · CPSC · pulled in by unpainted wood 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 sharpest edge on the page. The lead determination two rows up is the bare word “Wood”. This one spells out no added surface coatings and names varnish and paint. On a toy painted 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 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 the product type outright. Wood chips and paint flakes are not among the fragments excused — that list is paper, fabric, yarn, fuzz, elastic and string.
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. On wood, permanence usually means burning or engraving; we found no CPSC statement specific to wood.
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.
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. Both channels reach 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, and an 18-month to 3-year grading straddles that boundary. 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 18-month to 3-year 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 this example has not established: 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 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 stacking toy 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 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
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.
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 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.
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.
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 wood, points means splinters as much as spikes.
Third party? Yes to all five, at 16 CFR 1112.15(b)(32)(ii)(G), (H), (I), (O) and (R).
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
The coating, not the wood, is what sets the bill
Read the four chemistry rows together and a shape appears. Total lead, soluble heavy elements and phthalates each have a route by which wood leaves the laboratory — and on each of the three, the coating stays. The cost of testing a wooden toy is not really a question about wood.
The three routes are not even the same shape. For total lead the determination is the bare word Wood, with no condition about finish. For the soluble elements the definition names varnish and paint as disqualifying, so it reaches only surfaces left bare. For phthalates there is no CFR determination at all. Three rules, three reaches, one material.
Which is why the two decisions with the largest effect on the bill are made on the drawing rather than in the laboratory: which faces get coated, and whether the coating is locked to a part number.
One coating report can stand behind a whole range
16 CFR 1109.11(b) lets a coating be tested as a liquid, or as a dried film on any convenient substrate. The chemistry does not know what shape it was going to be painted onto, so one report for one coating can support every item that uses it, and a report the coating maker already holds can be relied on where 16 CFR 1109.5 is met. Nothing equivalent exists for the small-parts and mechanical work, which is measured on the finished article.
And one coating change undoes it
That concentration of value in the coating makes a quiet substitution the sharpest exposure here. 16 CFR 1107.23(d) counts a change of component supplier, and a different component part from the same supplier, as a material change — which sends samples back and produces a fresh certificate. Fixing the coating to a named maker and part number in the supply agreement does more work than testing after the fact.
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.
“United States (US): You will typically need a Children's Product Certificate (CPC) and a test report issued within the past 12 months by a CPSC-accepted laboratory. The report should confirm compliance with ASTM F963-23, phthalate restrictions, tracking label requirements, and small parts regulations.”
Amazon staff post, Seller Forums
An 18-month to 3-year grading sits on a seam
The use and abuse procedures are written for three bands, and a grading spanning more than one draws the most stringent requirements — which turns out not to be a property of either section. The drop is harder in 16 CFR 1500.51, ten from 4.5 feet against four from 3 feet, while torque, tension and compression are harder in 1500.52; CPSC says the same. What no CPSC document we could find settles is which combination governs a label spanning both bands, and 16 CFR 1501.4(b)(2) simply names both. So it is a question to put to the laboratory in writing.
“If an article is marked, labeled, advertised, or otherwise intended for children of ages spanning more than one of these age groups, the article will be subjected to the tests providing the most stringent requirements.”
16 CFR 1500.50(b)(1)(ii), eCFR
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.
Small batch relief, and why it does little here
The two tests that cannot be avoided here — lead in the coating, and small parts — are both in Group A, which small batch registration never reaches. CPSC also states that buying from a foreign manufacturer above the revenue or unit thresholds rules out small batch treatment for that product however small the importer is.
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
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. Here part 1303, 15 U.S.C. 1278a, part 1307, part 1250 with the individual F963-23 section numbers, and part 1501 all appear — with 16 CFR 1500.91(d)(4) named against the wood's total lead instead of a laboratory.
“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.
“Let me be clear: eFiling does not apply to domestic manufacturers, including small businesses manufacturing in the United States. It creates no new testing, certification, or compliance obligations. Importers are already required by law to create and maintain this information. eFiling simply modernizes how the data is transmitted to CPSC.”
CPSC Acting Chairman Peter A. Feldman, on eFiling
That statement is about eFiling. The amended certificate contents that started on the same date reach domestic manufacturers too.
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 this example has said about itself
Every line here is the invented importer's own answer, repeated back. Nothing was inspected, inferred or scored to produce it.
- Answered
Painted on every face, graded 18 months to 3 years, no magnet and no battery, built by an OEM factory in China, sold on Amazon and on the importer's own store.
- Answered
No certificate has been issued yet.
- Not answered
Whether any test report exists — from the factory, a previous buyer, or the coating maker.
- Not answered
Which coating is used: its maker, part number and data sheet, and whether it carries intentionally added PFAS.
- 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.
- No certificate exists
So there is nothing to eFile at entry, nothing to furnish to Amazon or a retailer, and nothing to produce within 24 hours. 16 CFR 1110.5, 1110.13.
- The coating is not identified
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 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.
Before that list can be closed
Everything shown above this line is reading published rules against stated facts, which is what the free scan does.
Everything above was settled by eight facts. Closing the list needs the real specification: the coating's composition and part number, the parts list including adhesives, which faces stay bare, and the exact age wording on the box.
Planned MooseClear is being built to take that 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.
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.
Questions you can send your supplier
Copy these into an email. They ask for facts a factory already has, and none of them assumes an answer.
- Do you hold any test reports for this product for the US market? If so, what is the issue date, the laboratory name, and the exact model or SKU each report covers?
- Were those reports issued under our name, or under another buyer's name?
- Have the materials, components, coatings, or the factory changed since those reports were issued?
- What age grading is printed on the product and on its packaging?
- What materials and components does the product contain, including any coating, filling, fabric, magnet, or battery?
- What permanent markings are applied to the product and to its packaging, and where exactly are they placed?
- Which company is named as the certifier on any certificate you hold for this product?
- Which laboratory carried out the testing, and is that laboratory listed in CPSC's public search of accepted laboratories?
Where this sample ends
The six stages above are the whole worked example. For the reading built around your own answers — what each sales channel publishes, the general checklist, and the rest — run the free scan. For a wooden toy, the category map renders these same stages against the facts you declare.
Important limits
- This preview does not determine which rules apply to your specific product. It does not determine applicable rules for any shipment.
- No legal advice is provided; results are an orientation aid, not a compliance determination.
Run your own free scan
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