If you are selling toys into the United States, two documents govern: ASTM F963, the voluntary standard that became mandatory, and CPSIA, the federal act that added lead limits, phthalate limits, tracking labels and third-party testing requirements. This checklist covers what your Chinese factory has to do differently for a US order compared with an EU order.
ASTM F963 scope
- Physical and mechanical. Small parts, sharp points and edges, projections, fasteners, seams, and the torque, tension and drop tests on attached components. Similar in spirit to EN 71-1 but with different acceptance values.
- Flammability. A specific test for toys that could ignite, using a defined ignition source and burn-rate limit.
- Toxicology. Lead in surface coatings and substrates, and soluble antimony, arsenic, barium, cadmium, chromium, lead, mercury and selenium. Limits are stricter than the general EU toy limits for lead in paint.
- Electrical. Where the toy has a motor, lights or batteries: temperature, insulation and battery compartment security.
CPSIA adds five things ASTM does not
- Lead in substrate. 100 ppm total lead by weight in any accessible component, not just the coating.
- Phthalates. DEHP, DBP and BBP are permanently prohibited at more than 0.1 percent in toys and child care articles. DINP, DIDP and DnOP are prohibited on an interim basis in the same category.
- Third-party testing. Toys must be tested by a CPSC-accepted laboratory before a Children's Product Certificate can be issued. A factory's own test bench is not sufficient.
- Tracking labels. A permanent mark on the product and packaging giving the batch or run number, so a recall can be scoped. This is the requirement most often missing on first shipments.
- GCC or CPC. A General Certificate of Conformity for non-children's products, or a Children's Product Certificate for children's products, filed with the test report.
What the factory has to do
- Use certified materials: lead-free pigments, phthalate-free plasticisers, and supplier declarations for every colourant.
- Apply the batch mark at the point of moulding, not as a label added later, so it survives handling.
- Sample production parts, not lab plaques, and send them to the accredited lab. Testing the wrong sample is the most common reason a compliant factory still fails.
- Keep the certificate and test report traceable to the batch, because a second production run is a new compliance event.
Cost reality
Third-party testing per SKU and per colourway is the real cost driver, not the testing itself. Factories that plan this from the start quote it as a line item; factories that do not will either absorb it badly or surprise you after tooling. Ask for the testing plan in the quotation, not after the tool is cut.
Related reading
Our multi-part action figure tooling programme is supplied with batch marking and phthalate-free certification, and the certification guides section covers the EU side in detail.
Related product categories
The materials and part types discussed above are grouped in our sourcing directory:
