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Last reviewed: September 2026 · Copy link

CPC certificates for arts and crafts kits

Children’s craft kits are certified like other children’s products (toy standard where applicable, lead limits, tracking labels) with one extra federal layer: the Labeling of Hazardous Art Materials Act (LHAMA) requires art materials to be evaluated and labeled for chronic hazards, with the statement “conforms to ASTM D-4236” on products and packaging.

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The two overlapping regimes

  • LHAMA / ASTM D-4236: every art material (paints, glues, markers, clays) must be reviewed by a toxicologist and labeled accordingly. This is a labeling duty on the product itself.
  • CPSIA: children’s products need third-party testing for lead and other applicable rules, plus the CPC citing them.

Kit composition drives the testing plan

A kit is many small products in one box: each material can need evaluation, which is why kit testing quotes vary so much. Consolidate materials, get supplier declarations for each component, and have the lab confirm the combined kit’s scope. The certificate then cites what the finished kit was tested for.

Questions people ask

Does the D-4236 statement replace the CPC?

No: D-4236 covers chronic-hazard labeling of art materials. Children’s products additionally need CPSIA testing and a CPC citing the physical and chemical rules.

Do crayons need lead testing?

Yes: pigments are a lead source. Reputable crayon makers test pigments; kit sellers should require the documentation from component suppliers.

Where does the D-4236 statement go?

On the product and/or packaging, per LHAMA labeling requirements. It is separate from the CPC document itself.

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