CPSC children's product certificates: what changed on 8 July 2026

Electronic filing of certificates of compliance with CBP became mandatory for most regulated consumer products. The certificate must still be issued by the US importer, not the foreign manufacturer.

A Children's Product Certificate is required for any product primarily designed or intended for children aged 12 and under. That includes children's clothing, toys, sports equipment sized for children, and school supplies.

The most commonly misunderstood point: the CPC must be issued by the US importer for products manufactured overseas. A certificate issued by the foreign manufacturer is not valid. The importer may base its certificate on the manufacturer's test reports, but the importer issues and signs it.

The certificate must be based on test results from a third-party, CPSC-accepted laboratory, covering every applicable children's product safety rule — which for a textile item includes flammability under 16 CFR 1610, and for a toy includes ASTM F963-23, lead content and phthalates.

From 8 July 2026, importers of most regulated consumer products must electronically file certificates of compliance with CBP at entry. Paper certificates presented on request are no longer sufficient for these products.

The practical consequence for sourcing is that third-party lab testing has to happen before shipment, not after. If testing is left until goods arrive, the entry cannot be filed correctly.

E-Com Market Place treats "is this intended for children aged 12 and under?" as a mandatory, enforced field at listing, because the answer changes the entire compliance path. Where the answer is yes, lab testing is scheduled before the production payment milestone, and the CPC is prepared for the importer to issue.