An overview of the most important toy safety laws every Promotional Consultant should know about toy safety. Consumer Product Safety Commission CPISA Feb 2012 update.

1. 8 Things Every Artistic Toy Employee
and Distributor Should Know
February 2012

2. How many types of safety tests are performed
on Toys?
1. Hazardous Conditions
2. Mechanical Safety
3. Chemical Requirements
4. Flammability
5. Performance
6. Labeling
6

3. How much does independent product safety
testing add to product unit cost?
Average
$0.65 cents / unit
Size MOQ CPSIA
Testing*
Unit Safety
Cost
3” 10,000 pcs $600 $0.06
5” 5,000 pcs $600 $0.12
8” 2,500 pcs $600 $0.24
12” 1,200 pcs $600 $0.50
24” 600 pcs $600 $1.00
36” 300 pcs $600 $2.00
* Assumes not plastic parts beyond eyes and beans
stuffing tested by an accredited CPC laboratory.

4. How much could you be fined for not
performing safety testing?
 The maximum civil penalties that the CPSC can assess
are for a violation and for
a series of related violations.
$100,000 $15 million

5. Do products manufactured before January 1,
2012 require Independent Safety Testing?
 If you are a manufacturer, importer, or private labeler of
toys, you must test your products manufactured
after December 31, 2011 for compliance with the toy
safety standard. The Commission will require third
party testing for those products on January 1, 2012. The
required testing must be conducted by an accredited
third party laboratory whose accreditation is accepted
by the CPSC.
NO

6. What do you provide customers when a product
was manufactured before January 1, 2012?
 General Conformity Certificate (GCC) – If a product
was manufactured prior to 1/1/12 and not independently
safety tested the supplier provides the GCC as a
declaration of the products conformity and testing
performed.
 Certificate Of Compliance (COC) – If a product was
manufactured prior to 1/1/12 and independently safety
tested the supplier provides a COC.
GCC / COC

7. When is the product safety information required
to be provided to customer?
 Toy safety information must be available for U.S.
Customs Inspection or products could be held at
port.
 Products manufactured (assembled) in U.S. require
product safety information at date of shipment.
Upon Shipment Date from Factory

8. Do we have to independent safety test an order for
100 pcs of a stock bear with a screen printed t-shirt?
 If the supplier has policies and control procedures
in place to ensure that safety testing was performed
on the toy and the inks used were safety tested then
reliance on the initial safety testing can be used as
long as there is not change in raw materials or ink
providers.
NO

9. What determines law label language?
Importer of Record
Laws applicable in the country of planned distribution
Regulation
Number
Batch Identifier
Toy Content
Country of
Origin
European
Conformity Logo