CPC for children’s promotional products

Which rules apply to children’s promotional products

• Promotional products for children (branded toys, giveaway items, event merch) are children’s products with the full CPSIA duty set: third-party testing, a CPC in the distributor’s or importer’s name, tracking labels, and lead/phthalate screening — giveaways at events are sales into commerce.
• 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

The recurring failure: companies treat promotional giveaways as marketing expenses rather than products, skipping certification entirely. Enforcement actions and marketplace policies treat a branded giveaway toy exactly like a retail product — the certificate, testing, and labeling duties are identical.

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

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