ComplyMyImport guide

Toy Import Compliance Checklist for US Importers

Toy compliance is easier to manage when the work begins during product development and sourcing, not when a shipment is already moving. This checklist gives small US importers and e-commerce brands a practical framework for organizing CPSC compliance evidence for non-electronic children's toys and accessories.

It is an operational starting point, not a universal legal determination. The exact requirements depend on the product's design, intended users, materials, components, manufacturing process, and current regulations.

1. Define the exact product

• Assign a stable product name, SKU, model, and version
• Record intended age grading and foreseeable use
• Capture dimensions, materials, coatings, components, and variants
• Identify the supplier and finished-product factory
• Keep product photographs, packaging, instructions, and artwork together

Avoid grouping materially different products under one record merely because they share a marketing name. The evidence must identify what it covers.

2. Determine which CPSC rules apply

• Evaluate whether the item is a children's product
• Identify product-specific mandatory standards
• Evaluate applicable ASTM F963 provisions for toys
• Consider lead, phthalates, small-parts, and other component or use-specific rules
• Record the rule-pack version and reasoning used for each result
• Escalate uncertain classifications for qualified review

Applicability should be reproducible from product facts and current rules. A generic laboratory test menu is not a substitute for this analysis.

3. Plan and verify third-party testing

• Match each required test to a CPSC-accepted laboratory facility
• Verify that facility's scope for the specific rule or method
• Provide the laboratory with accurate product and material details
• Confirm the tested sample matches the product to be imported
• Retain complete reports, photographs, dates, and laboratory details
• Identify any missing, inconclusive, or conflicting results

Laboratory acceptance is facility- and scope-specific. A partner relationship or prior project does not prove eligibility for a new requirement.

4. Review tracking labels and packaging

• Confirm the product and packaging carry required identifying information where applicable
• Connect batch, run, manufacture-date, or other distinguishing marks to production records
• Review permanence, legibility, placement, and consistency
• Check warnings, age grading, instructions, and packaging against product facts
• Retain the approved artwork version and review decision

Tracking-label compliance is separate from the CPC's required rule citations. Label artwork should still be reviewed as part of the complete product record.

5. Prepare the Children's Product Certificate

• Identify the exact covered product
• Cite each applicable children's product safety rule
• Add the responsible importer information
• Add the test-record custodian's contact information
• Record the date and place of manufacture
• Record the date and place of testing
• Identify each CPSC-accepted testing laboratory
• Have an authorized representative review and approve the certificate

Do not treat extracted data or a generated draft as an issued CPC. The importer remains accountable for certificate accuracy.

6. Prepare CPSC eFiling and broker handoff

• Decide whether the shipment will use a Full or Reference PGA Message Set
• Validate the required certificate data against approved evidence
• For the Reference path, retain the CPSC Certifier ID, Product ID, and Version ID
• Give the customs broker the correct identifiers or complete certificate data
• Provide shipment and product mapping needed for entry lines
• Track Product Registry, broker-transmission, and ACE-response states separately

The customs broker handles the customs entry and ACE transmission. A product-compliance system should provide controlled, reviewed inputs without claiming that a shipment has cleared.

7. Maintain the record after approval

• Preserve the approved certificate and supporting reports
• Track supplier, material, design, process, and factory changes
• Reassess testing after relevant material changes
• Monitor periodic-testing and recordkeeping obligations
• Version revised certificates instead of overwriting approvals
• Keep evidence requests, overrides, approvals, and exports auditable

ComplyMyImport provides a product-level workflow for these records, evidence gaps, certificate preparation, and broker handoff. It supports human decisions; it does not replace the importer, laboratory, customs broker, regulator, or legal counsel.

This checklist is general educational information and is not legal or customs advice.

Official resources

• CPSC Children's Product Certificate guidance: cpsc.gov/cpc
• CPSC testing and certification: cpsc.gov/Business--Manufacturing/Testing-Certification
• CPSC eFiling guidance: cpsc.gov/eFiling