Compliance
US: CPSIA, ASTM F963-23 and the CPC
This page is the reference version of the US requirement for 0–3 wooden toys. It states what applies, what evidence exists for it, and who is responsible for signing. For the walkthrough version, see CPSIA and the CPC for wooden baby toys.
Core position: the CPC is issued by the US importer or US domestic manufacturer. We supply the test report and the production data behind it. We do not issue CPCs.
Requirements at a glance
| Requirement | Detail | Evidence | Signed or held by |
|---|---|---|---|
| Toy safety standard | ASTM F963-23, mandatory through 16 CFR 1250.2; CPC must cite applicable sections | Third-party report naming sections | Lab report; importer signs CPC |
| Small parts, under 3 | 16 CFR 1501 — no small parts; 1500.18(a)(9) makes a small part a banned hazardous substance | Abuse and small-parts testing | Lab report |
| Rattles | 16 CFR 1510 — no full insertion into the test cavity before or after abuse | Rattle-specific test | Lab report |
| Lead in coating | 16 CFR 1303 — 90 ppm | Coating test | Lab report |
| Total lead, substrate | 15 U.S.C. 1278a — 100 ppm | Substrate test | Lab report |
| Phthalates | 16 CFR 1307 — eight substances at 0.1% | Component screening | Lab report |
| Tracking label | 15 U.S.C. 2063(a)(5)(A) — four elements, product and packaging | Label artwork and photo record | Factory prints; importer confirms |
| Certificate eFiling | From 8 July 2026, certificate data filed electronically via PGA Message Set | Structured certificate data | Importer or customs broker |
The standards that matter for a wooden toy
ASTM F963-23 is the current mandatory version. A report against F963-17 does not evidence conformity to the version referenced by 16 CFR 1250.2. The CPC should list the F963 sections that apply to the product, with a section applicability table behind it.
16 CFR 1501 is the rule buyers underestimate. For a toy intended for a child under 3, any small part that detaches under normal use or foreseeable abuse makes the product a banned hazardous substance. There is no warning-label route out. The design response is joint construction, dowel diameter, component size and glue performance.
16 CFR 1510 applies to rattles. The requirement is that the rattle, or any part of it, cannot be inserted entirely into the test cavity — and that this holds after the abuse tests, not only before.
16 CFR 1251.2 gives untreated, unfinished solid wood a limited exemption from F963 heavy-element limits, on the basis that the material is highly unlikely to exceed them. It does not extend to engineered wood — plywood, MDF, fibreboard — and it does not cover painted or varnished surfaces.
The CPC: seven elements
- Product identification, specific enough to match the model and SKU.
- Citation to each CPSC rule the product is certified against.
- Name, full mailing address and telephone number of the issuing US entity.
- Contact details for the person maintaining test records.
- Date and place of manufacture.
- Date and place of testing.
- Identification of the third-party laboratory, including its CPSC acceptance.
The certificate must be available to distributors and retailers, and from 8 July 2026 its data must be electronically filed. A scanned PDF in an email thread is not a filing system.
What we supply, and what stays with the buyer
| Item | We supply | Buyer does |
|---|---|---|
| Test report per model | Yes, with lab name, edition, date, sample scope | Holds and files |
| Component and material breakdown | Yes | Passes to lab |
| Factory identity and production dates | Yes | Enters on CPC |
| Batch numbering scheme | Yes | Confirms and records |
| Tracking label artwork and data sheet | Yes | Approves artwork, prints |
| CPC signature | No | Signs as importer or domestic manufacturer |
| eFiling submission | Data support | Files through broker or system |
How to verify a report before you accept it
- Laboratory is CPSC-accepted, and the scope covers the test performed.
- Sample description matches your model, colour and materials.
- Standard edition is F963-23 where F963 applies.
- The clauses are listed: 1501, 1510 where applicable, 1303, 1307, F963 sections.
- Test date precedes production date.
- Report is signed by the lab and traceable to a sample.
If any of the six fails, the report is not a basis for a CPC for your shipment.
FAQ
Q: Does every wooden baby toy need a CPC?
A children's product intended for children 12 or younger needs a CPC. A 0–3 wooden toy is squarely in scope.
Q: Do you provide the CPC for us?
No. We provide the report and the data. The CPC is signed by the US importer or US domestic manufacturer.
Q: Is eFiling already in force?
The requirement applies from 8 July 2026. Certificate data must be filed electronically with CBP through the PGA Message Set. Confirm the current implementation details with your broker.
Q: What if our supplier's report is F963-17?
It does not evidence conformity to the current mandatory version. Ask for a retest or an amendment against F963-23 before relying on it.
Related pages: EN 71 and CE for the European counterpart and the guide to US tracking labels. For model-level report status, use the quote form.
This is a commercial explainer, not legal advice. Certification is model-specific and market-specific.
Tell us the model and the market
We confirm whether a report exists, or whether testing can be commissioned.