FAQ
Q: My product is labelled “14+”. Do I still need to follow children’s toy standards?
A: It depends on the market. In the
US, CPSC looks at function, appearance, marketing channels, and advertising audience—not just the label. A colourful
blind box might be collected by adults, but regulators could reasonably argue it also appeals to younger kids. If they do, you’re on the hook for full CPC compliance. In the
EU, the new regulation clarifies that if a parent or guardian could reasonably infer from a product’s function, size, and characteristics that it’s intended for children under 14, it’s a toy—regardless of what the label says. In
China, the new art toy standard is specifically for 14+ products, but until it’s finalised, many products still get evaluated against children’s toy criteria.
Q: What’s the Digital Product Passport and when do I need it?
A: The DPP is a QR code (or similar data carrier) on every toy sold in the EU that links to full compliance information: CE marking, safety warnings, batch info, material composition, conformity assessment reports, and recall history. The new Toy Safety Regulation (EU) 2025/2509 entered into force on January 1, 2026, with full application starting August 1, 2030. You have a transition period until 2030, but early preparation is recommended.
Q: What’s the difference between CPC and CE certification?
A: CPC (Children’s Product Certificate) is a US requirement—a self-declaration document issued by the manufacturer or importer based on testing at a CPSC-accepted lab. CE marking is an EU requirement—a declaration that the product meets all applicable EU health, safety, and environmental requirements. They are not interchangeable; you need both if you’re selling in both markets.
Q: Which chemical limits are the strictest?
A: Generally, the EU has the broadest chemical coverage (19 heavy metals in EN 71-3 plus extensive organic compound restrictions). China’s new GB 6675-2025 adds requirements the other two don’t have—VOC/TVOC release, formaldehyde, azo dyes, PAHs, and allergenic fragrances. The US focuses heavily on total lead (coating ≤90 ppm, substrate ≤100 ppm) and phthalates (8 types, each ≤0.1%). For specific substances like decabromodiphenyl ether (decaBDE), the EU sets the strictest limit (non-electric toys ≤0.001%), while the US allows ≤0.1%.
Q: Do I need to test every batch?
A: In the US, the CPC covers each production batch, and you must maintain test records. In practice, many manufacturers test initial production runs and then conduct periodic batch testing, but the legal requirement is per batch. In the EU, the Declaration of Conformity covers the product design; ongoing compliance is the manufacturer’s responsibility. Under the new DPP system, batch-level traceability will be significantly enhanced.
Q: My art toy has a light-up base with batteries. Any special requirements?
A: Yes. In the EU, the new TSR requires that batteries be designed so they cannot be accessed without tools; if the toy’s size or characteristics make that impractical, rechargeable batteries can be designed as non-removable structures, replaceable only by professionals. In the US, electric toys must also meet additional electrical safety requirements under 16 CFR Part 1505.
Q: What about VOCs—volatile organic compounds?
A: This is becoming a major focus. China’s new GB 6675-2025 includes specific VOC/TVOC release requirements that are more explicit and demanding than those in the US or EU. For art toys, which often use paints, adhesives, and clear coats, this is particularly relevant. The new Chinese art toy standard (under development) is expected to include VOC limits based on the existing group standard T/CPQS C011—2023.
Q: How do I choose a testing lab?
A: For the US, the lab must be CPSC-accepted. For the EU, labs should be ISO 17025 accredited. For China, use accredited domestic labs. A good rule of thumb: ask which market, which standard, which product, and which test report. Don’t ask whether a supplier is “internationally certified”—ask for the specific report.