Home / Guides / CPC for pacifier clips

Last reviewed: September 2026 · Copy link

CPC for pacifier clips

Pacifier clips designed or marketed to children 12 and under are children’s products: they need third-party testing at a CPSC-accepted laboratory and a Children’s Product Certificate citing small parts, lead, and labeling rules, plus tracking labels on the product and packaging. The importer or US manufacturer issues the CPC — marketplaces can request it at any time.
On this page
Which rules apply to pacifier clipsThe testing and certification path
Generate this CPC free

Which rules apply to pacifier clips

  • Pacifier clips combine small parts and lead testing with design review of cords, beads, and attachment hardware — and marketing claims matter: teething-jewelry-style positioning draws CPSC scrutiny.
  • 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 small parts on beads and embellishments, lead in substrates and coatings, and pull/impact strength of the cord, ribbon, and clip mechanism. Products marketed to relieve teething get heightened scrutiny because they go in the mouth.

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

Are amber teething necklaces legal to sell?

They are not federally banned, but the CPSC has warned against them for choking and strangulation, and several marketplaces restrict them. Selling them as teething relief for infants is a claims and enforcement risk.

Do clips need the same rules as pacifiers?

Pacifiers themselves have a dedicated rule; clips cite the general children’s rules. The clip tests its own hardware — the pacifier is the consumer’s.

Related guides

CPC for pacifiers and teethers

Pacifiers have their own federal standard (16 CFR Part 1511) plus phthalates and lead rules. Teether certifica…

CPC for teething jewelry

Teething jewelry for children 12 and under need a Children’s Product Certificate citing small parts, lead, and…

Small parts testing: 16 CFR Part 1501

16 CFR Part 1501 bans small parts in toys for children under 3. How the small parts cylinder test works, which…