What CPSIA actually asks of a wooden toy
CPSIA is the 2008 US law that changed how children's products are tested and certified. For a wooden toy it produces four obligations: lead limits, phthalate limits, conformity with ASTM F963 at 16 CFR 1250, and a Children's Product Certificate backed by testing at a CPSC-accepted third-party laboratory.
"Children's product" means an item designed or intended primarily for children 12 and under. A wooden puzzle sold to a toy shop is one. The same puzzle sold as a decorative object to adults is not, but the moment the packaging shows a child or carries an age grade you have declared your intent.
Two points settle most arguments. Lead limits apply to accessible parts, meaning what a child can reach and mouth. And the certificate is issued by the importer, not the lab: the lab produces data, you sign the CPC.
Two lead limits, not one: 100 ppm and 90 ppm
There are two separate lead limits in US law and they apply to different things.
- 100 ppm: total lead in any accessible substrate of a children's product. Wood, plywood core, MDF, a plastic bead, a metal screw, a cord.
- 90 ppm: lead in paint and other surface coatings, from the lead paint rule at 16 CFR 1303, which CPSIA kept.
CPSIA phased the substrate limit from 600 to 300 to 100 ppm by 2011. The coating limit was already 90 and did not move. Because 90 is lower than 100, a paint at 95 ppm passes the substrate rule and fails the coating rule. Quoting one number for the whole toy is how that gets missed.
The tests differ too. The US lab scrapes the dry film and measures total lead; EN 71-3 measures migration into a simulated stomach fluid. A dual-market product needs both, and a lab calling EN 71-3 equivalent is offering the wrong document.
Which parts of a wooden toy get tested
A painted wooden toy is not one material. Walk the bill of materials and test every material a child can touch:
| Part | Material | Test | Limit |
|---|---|---|---|
| Body, blocks, puzzle pieces | Bare or painted wood | Substrate lead | 100 ppm |
| Paint, lacquer, clear coat | Surface coating | Total lead in coating | 90 ppm |
| Plywood, MDF core, adhesive | Composite substrate | Substrate lead | 100 ppm |
| Plastic knobs, wheels, windows | Plastic, possibly PVC | Lead and phthalates | 100 ppm, 0.1% |
| Cord, string, elastic, ribbon | Fibre or plasticised | Lead, phthalates, cord rules | 100 ppm, 0.1% |
| Screws, hinges, magnets | Metal | Substrate lead, magnet rules | 100 ppm |
Packaging sits outside the lead limits, but the polybag still needs its suffocation warning.
Phthalates: not only plastic toys
CPSIA restricts six phthalates at 0.1% each, or 1,000 ppm, in children's toys and child care articles: DEHP, DBP, BBP, DINP, DIDP and DnOP. For the last three it covers items that can be placed in a child's mouth. Check the current text at 16 CFR 1307 rather than a spec sheet written in 2019.
They do not come from the wood, and usually not from the water-based paint. They come from plasticised PVC: soft knobs, vinyl decals, some screen-print inks, coated cords, mirror films, the soft grip on a pull-along handle. With no plasticised parts the screen is short. With one, that component decides the result. Ask for testing per plastic component, not per SKU. A report saying "phthalates: pass" without listing the components cannot be defended when a supplier quietly changes a knob.
Why the age grade changes the rules
Age grading is not a marketing line. It sets which rules apply before a single test is run.
- 12 and under: a children's product, so lead, phthalates, ASTM F963, a CPC and a tracking label all apply.
- Under 3: the small-parts prohibition at 16 CFR 1501, more aggressive use and abuse testing, and an assumption that the toy will be mouthed.
- 3 and over with small parts: the design rule relaxes to a warning statement.
Moving a product from 3+ to 2+ does not reduce testing, it increases it, and it can invalidate the report you hold. The grade must also be defensible: a chunky knob puzzle aimed at a two-year-old cannot be graded 6+ to dodge the small-parts rule.
The lab, the report and the CPC
Testing must be done by a CPSC-accepted third-party laboratory, accredited for the specific method, with the report issued in the name of the party relying on it. A report without that acceptance is not evidence, whatever the results table says.
The CPC is a one-page document with specified contents: the product it covers, each CPSC rule it conforms to, the manufacturer or importer certifying, the records custodian's contact details, the date and place of manufacture, the date and place of testing, and the laboratory that did the testing. Miss the custodian or the place of manufacture and a retailer sends it back.
How one report covers forty SKUs
Testing every SKU is not the only lawful route. One report can cover a family when construction, materials and process are the same and the laboratory agrees in writing that the group is equivalent. What has to match: construction and dimensions within a stated tolerance; timber species, grade, board thickness and board supplier; the paint and ink system, same supplier and same number of coats; hardware, factory, process and age grade.
Colour variants can be covered where only the tint changes, and the lab will usually ask for the worst case, often the darkest colour. What breaks a family: a new paint supplier, water-based switched to solvent, a different board thickness, a plastic window added for retail, a new knob, or laser engraving introduced where there was none. Any of those voids the report for the changed SKU even where the sibling is untouched.
What to keep and what to hand a retailer
Keep the CPC per SKU, the full reports, paint and ink declarations, component certificates for bought-in parts, colour formulation records and the tracking-label artwork. Keep them for the life of the SKU and beyond: a retailer asks for recent reports, and the next lab wants the earlier one to justify a sister-SKU comparison.
The tracking label is a separate obligation. Children's products need a permanent mark on the product and packaging showing the manufacturer, the location and date of production, and the batch or cohort. On a wooden toy that is usually laser-etched or stamped on the base, with the same information printed on the box. A sticker is what most factories offer if you do not specify, and a sticker is not permanent.
Next step
Send the SKU list with the age grade and colourways, and we will return the CPSIA reports on file, the parts list showing which components were tested as substrate and which as coating, and a CPC draft for your importer signature. Every model in the 910-SKU catalogue carries per-model EN 71 and ASTM documentation, described under quality and certifications. Start with the baby and toddler range, or request a quote with the age grade you intend to sell at.
