| 🇺🇸 This guide applies to merchants shipping children's products into the United States. It expands on Path 1 of The Swap guide to CPSC eFiling for US imports.
If you sell products designed for children aged 12 or under, US law puts you on the certification path. You cannot use a disclaim, there is no self-testing route, and no declaration Swap can file substitutes for it. Certification takes weeks to months and has associated costs. The earlier you start, the fewer held shipments you'll see.
This guide walks through the process end to end.
Step 1: is it a children's product?
A children's product is one designed or intended primarily for children 12 years of age or younger (15 U.S.C. § 2052(a)(2)). Four things decide it:
What you, the manufacturer, say the product is for
How it is packaged, marketed and advertised
Whether consumers commonly recognise it as being for children under 13
CPSC's Age Determination Guidelines
Baby and infant products are always in scope. Childrenswear is in scope. A product doesn't escape by being "unisex" or "for the whole family" — if it's primarily intended for under-13s, it's a children's product.
⚠️ Don't confuse the two age lines. A children's product is for age 12 or under. The intended use code 130.006 used with disclaims covers people aged 13 or older. They are different scales — a product can't be both.
If you sell a mix of adult and children's lines, split your catalogue now. Your adult lines usually resolve to a disclaim quickly (see the main eFiling guide), and even adult products that do need a certificate only need a General Certificate of Conformity, which does not require third-party lab testing. Don't let the adult side of your catalogue wait behind the children's work.
The path at a glance
Step | What you do | Who does it |
1 | Confirm which products are children's products | You |
2 | Identify every children's product safety rule that applies | You (CPSC's Regulatory Robot helps) |
3 | Test at a CPSC-accepted third-party laboratory | Your lab partner |
4 | Issue a Children's Product Certificate (CPC) | You |
5 | Create a Business Account in the CPSC Product Registry | You (once) |
6 | Register each product to get its Product ID and Version ID | You |
7 | Send your three IDs to Swap | You |
Step 2: which rules apply?
Each children's product must be tested against every rule that applies to it. Common examples for apparel and children's goods:
Total lead content, and lead in paint or surface coatings
Phthalates (plasticisers)
Flammability of clothing textiles, and the stricter children's sleepwear standards
Small parts (choking hazard)
Button and coin cell batteries (16 CFR part 1263)
The fastest way to build your list is CPSC's Regulatory Robot — a free questionnaire that outputs the requirements for your product. The output is your determination, which is where it legally belongs: Swap cannot make it for you.
Step 3: third-party lab testing
For children's products, testing by a CPSC-accepted third-party laboratory is mandatory. You cannot test in-house, and a supplier's assurance is not enough. Find accepted labs at cpsc.gov/labsearch.
Testing is charged per test, per rule, and it is the real expense in this process — the certificate and registration are administrative by comparison. If you're budgeting, this is the line.
💡 One fabric exemption trap: if your children's garment is made from fabric that's exempt from flammability testing under 16 CFR 1610.1(d), you still need a CPC — children's products always need one. The exemption only changes what supports the certificate (you cite the testing exclusion instead of flammability test data). Other applicable rules, like lead content, still need testing.
Step 4: the Children's Product Certificate
Your CPC is issued by you, based on the lab's test results. It must contain the seven elements at 16 CFR 1110.11, including:
Identification of the product
Each rule the product is certified to
Your details as the certifying importer
Manufacturer name and full address
Date and place of manufacture (to at least month and year)
Date and place of testing, and the lab's details
A contact for the test records
Collect the manufacturer and date-of-manufacture details early — the same information is needed for customs (MID) purposes, so gathering it once serves both.
Steps 5–6: the CPSC Product Registry
Self-register a Business Account at the CPSC Product Registry. This generates your Certifier ID. You only do this once.
Enter each product's certificate data — one at a time in the portal, or in bulk by CSV or API (template and user guide in CPSC's eFiling Document Library). Registering returns the product's Product ID and Version ID.
You can group variants. Colours and sizes of the same product — same materials, same manufacturing site, covered by the same test results — can sit under one registration. What you can't do is cover a whole range with one certificate: each certificate describes only one product (16 CFR 1110.13(a)). Where it's borderline, register per style.
⚠️ There is a short editing window after certifying a product in the Registry (currently understood to be 48 hours). After it closes, any change means a new Version ID — which you'll need to re-send to Swap. Double-check entries before certifying.
Step 7: send Swap your three IDs
For each registered product, Swap needs:
Value | Swap field |
Certifier ID |
|
Product ID |
|
Version ID |
|
Your Account Manager will confirm the best route for your account (CSV upload, API, or direct Shopify metafield entry). Until these IDs are transmitted at customs entry, affected shipments can still be held — a certificate sitting in the Registry, or a file sent to Swap, doesn't clear a parcel by itself.
🛑 If you've paused US shipping: don't resume until your three IDs are issued and confirmed with Swap. Resuming earlier means new shipments join the held queue.
Your obligations don't end at registration
These are the ongoing requirements brands most often miss:
Periodic retesting — at least annually; every two years if you have a documented production testing plan; every three years if you use an ISO/IEC 17025-accredited lab
Material changes — any change to design, manufacturing process or component sourcing requires new testing and a new CPC
Records — keep certificates and test reports for five years, and be able to produce them to CPSC or US Customs within 24 hours of a request
Keep your Version IDs current with Swap — a new certificate version means a new Version ID on your shipment data
What does it cost, and can you reduce it?
CPSC doesn't publish a fee for the Product Registry itself — if you need certainty on that, [email protected] will confirm in writing. The real cost is lab testing.
The one thing that genuinely reduces the bill is the small batch manufacturer route (15 U.S.C. § 2063(d)(4)). If your revenue and US unit volumes are under the current thresholds, you can register annually as a small batch manufacturer at saferproducts.gov, and certain rules — including clothing flammability and children's sleepwear — then allow first-party testing or a supplier's written assurance instead of accepted-lab testing. Two caveats: the thresholds change every year, so check the current figures, and it doesn't apply to every rule — it narrows the bill rather than removing it.
What Swap can and can't do
We can: map your catalogue against CPSC's flagged HTS list, suggest 10-digit HTS codes, carry your certificate IDs onto shipment data, and work with the carrier on held parcels.
We can't: decide whether your product is a children's product, choose which rules apply, or act as the certifier. Under 16 CFR 1110.7(a) the importer is the certifying party, and the attestation is made under US law. The determination and the signature are yours; the mechanics around them are ours.
Helpful links
eFiling Document Library (bulk upload template and user guide)
This guide is provided for informational purposes. As the importer and certifying party, you're responsible for the accuracy of your certification and registration data. Swap Commerce does not register products or certify compliance on your behalf.