| 1 | Map every accessible material Ask for a bill of materials covering the shell, paint, buttons, wires, battery compartment, and accessories. | Lead limits apply to accessible component parts of children’s products. Scope depends on the product and applicable rules. | Material list, component drawings, and identification of coatings, plastics, and metal parts. | Check that the documents cover the finished toy and all included parts, not just the outer shell. |
| 2 | Check total lead in accessible components Review each relevant material or component separately. | The general CPSIA limit for lead content in accessible component parts is 100 ppm, subject to applicable statutory provisions and exemptions. | Test reports identifying the tested component, material, method, result, and applicable limit. | Confirm results are tied to the same material and construction used in the product being purchased. |
| 3 | Screen paint and other surface coatings Include printed details, decorative finishes, and colored coatings. | The CPSIA limit for lead in paint and similar surface coatings is 90 ppm. | Coating-specific test results and a description of the tested color and finish. | Check multiple colors or finishes where their formulations differ; a report for one coating may not cover another. |
| 4 | Request phthalate testing for relevant materials Pay particular attention to flexible plastics, soft parts, and coatings. | For children’s toys and child care articles within the rule’s scope, each of the eight restricted phthalates is limited to 0.1% (1,000 ppm) in accessible component parts. | A report listing the phthalates tested, individual results, tested materials, and product identification. | Verify that the report addresses all eight restricted phthalates, rather than relying on a general “phthalate-free” statement. |
| 5 | Verify testing and certification responsibilities Check that testing is appropriate for the product and applicable requirements. | Where required, children’s products must be tested by a CPSC-accepted third-party laboratory. The responsible manufacturer or importer issues the Children’s Product Certificate (CPC). | Applicable test reports and a CPC identifying the product and relevant rules. | A test report supports certification; it is not itself a substitute for the required CPC. |
| 6 | Match documents to production lots Ask how material or factory changes are controlled. | Children’s products generally require tracking information that helps identify the manufacturer or private labeler, production location and date, and batch or run information, to the extent practicable. | Sample tracking-label details, lot records, and a process for notifying buyers of material or supplier changes. | Confirm test evidence and production records refer to the same model and controlled materials. |
| 7 | Agree on corrective action before ordering Set expectations for failed tests, changes, and updated reports. | A product must meet the applicable requirements; a passing result for one sample does not establish that changed materials or later production comply. | Written procedures for nonconforming materials, retesting, change approval, and record retention. | Prefer documented controls that require review before changes to plastics, coatings, components, or production sites. |