Toy Safety Tips

Consumer, Children’s, and Licensed Products

Ensure your Consumer Products are Market Ready before they are produced!

Rachel Murray Meyer

Toy Safety and Quality, Inc

San Francisco CA 94118

Phone: (415) 379-9161

How to Navigate Toy Safety Requirements:

A Manufacturer’s Executive Summary for Successfully Bringing Toys to Market-

Best Practices for Avoiding Recalls,

Compliance with CPSIA and the Testing and Labeling Pertaining to Product Certification Rule

© Rachel Murray Meyer 2013 (updated 2018)

In the summer of 2007 millions of toys were recalled. Consumers Union labeled 2007 “The Year of the Recall”. Most of these recalls were for design related issues such as small powerful hazardous magnets and small parts in toys for children under three years old. The rest were primarily for lead. An Act of Congress, The Consumer Product Safety Improvement Act of 2008 (CPSIA) was created to address these issues. There are new rules regarding the certification of children’s products, see below.

9 Tips for Avoiding Recalls

1. Commit to Safe Toys throughout the supply chain, from design through raw materials, manufacturing, packaging and distribution. Make sure your suppliers have proper policies and procedures in place and that they are documented.

2. Know the Age Group for which the toy design is appropriate. Proper age grading determines the design and test requirements. Especially look out for small parts, which can pose choking hazards for children under three. Visit the CPSC website to download the complete 2018 Draft CPSC Age Determination Guidelines updated from 2002 Guidelines (2.7MB PDF).

3. Certify that your toys are safe per CPSIA and Rule 16 CFR 1107, which is effective February 8, 2013. See section below.

4. Comply with the Federal Legislation of the Consumer Product Safety Improvement Act (CPSIA) (2008) and frequent the U.S. Consumer Product Safety Commission CPSIA website for updates.

5. Design safe toys. Go beyond a review of the regulations and standards. Toy concepts and designs need to be evaluated to understand if they pose any potential hazards during use and foreseeable abuse, and what is the risk of such hazards occurring.

6. Keep up to date on the toy industry at the Toy Industry Association (TIA) website.

7. Make sure that the quality and safety requirements are clear and agreed to by the manufacturer. Document the requirements and consider if legal counsel is needed.

8. Check out the U.S. Consumer Product Safety Commission (CPSC) website.CLearn about items that are being recalled. Explore the site and see the rules and regulations. Also see what consumers are saying.

9. Play with your toys! Also, get feedback from your kids, grandkids and your employee’s kids!

CPSIA and the Testing and Labeling Pertaining to Product Certification Rule

1.Key Requirements of the CPSIA:
a)Limits the total amount of lead in children’s product components to 100 ppm
b)Reduces the limit for lead in paint and surface coatings to 90 ppm
c)A General Conformity Certification (GCC) or Children’s Product Certificate (CPC) – (see point 2. below)
d)Third party testing – look for CPSC approved labs
e)Tracking Labels for children’s products
f)ASTM F963, the Toy Safety Standard, is mandatory
g)Limits for certain Phthalates in certain products

2.Certifications for children’s products including toys are required. Learn about Testing and Labeling Pertaining to Product Certification (Rule 16 CFR 1107 effective date February 8, 2013), for both Importer’s of Record and Domestic Manufacturers: link
An overview of the process:
a)Representative samples are submitted for testing to a CPSC approved lab
b)Periodic Testing, at least annually, unless certain conditions met
c)A significant or Material change may require additional testing
d)Manufacturers must establish procedures to safeguard against the exercise of undue influence on a third party lab
e)Record keeping: Manufacturers must keep records for at least 5 years that include copies of the Certificates, certification test records for each manufacturing site, test results, records of material change and periodic testing and production test if applicable. Document what you do!
f)Manufacturers may indicate with a label that the product complies with a CPSC rule or ban per specific requirements.

3.Determine if testing on components (this includes paint) could be performed instead of finished products or as a way to further strengthen the quality system and ensure compliance, using rule 16 CFR 1109 “Conditions and Requirements for relying on Component Part Testing or Certification, or Another Party’s Finished Product Testing or Certification, to Meet Testing and Certification Requirements.” link

4.Learn about the Toy industry Safety Standard, ASTM F963-17. Requirements address a variety of hazards and test methods. In the 2011 version of ASTM F963 there are added restrictions on Heavy Metals in the substrates of toys, in addition to the surface coatings. Meeting these requirements was mandatory as of June 2012 and third-party testing to ASTM F963-11 is required beginning June 10, 2013.

Rachel Murray Meyer is a consumer product compliance consultant
And the principal of Toy Safety and Quality, Inc.