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Last reviewed: September 2026 · Copy link
CPC for children’s paint-by-numbers sets
Which rules apply to children’s paint-by-numbers sets
- Paint-by-numbers sets for children combine the children’s rules (lead in the canvas coating and paints, phthalates in pots) with LHAMA: every paint is reviewed by a toxicologist and labeled, and the set is certified with those duties on its CPC.
- CPSIA section 101 total lead content in accessible substrate materials.
- 16 CFR part 1303 lead in paint and surface coatings where painted or coated.
- CPSIA section 103 tracking labels: manufacturer, location, and date of manufacture on product and packaging.
The testing and certification path
Testing covers lead and heavy metals in each paint color (every pot is a formulation), the canvas coating, and brush ferrules; plus the LHAMA documentation file. Paint pots are small-parts candidates for under-3 grading — most sets grade 3+ or 5+.
Book testing at a laboratory that is CPSC-accepted for each rule, issue the CPC in your own name citing the rules your report supports, and keep the certificate with its test report for at least five years. Marketplaces ask for the pair, not the certificate alone.
Questions people ask
Do water-based paints still need testing?
Yes: “water-based” describes the carrier, not the safety. Each color is tested for lead and heavy metals, and the LHAMA review covers the formulation.
What should the paint labels say?
LHAMA-compliant labeling from the review: product identity, chronic-hazard warnings where applicable, and safe-use guidance. Blanket “non-toxic” claims without the review file are the violation.
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