ComplyMyImport guide
Small parts requirements for children's toys
Small parts can present a choking hazard to young children. US requirements may prohibit certain small parts in products intended for children under three and may require warnings for certain products intended for older children. The exact analysis depends on age grading, product design, and applicable rules.
Begin with intended age and use
Document how the product is designed, marketed, labeled, and reasonably expected to be used. Age grading should be consistent across the product, packaging, instructions, online listing, and testing request.
Do not use a higher age label merely to avoid a requirement. CPSC may consider product characteristics and marketing in addition to the stated age.
Identify accessible parts
Review the product as received and after applicable use-and-abuse testing. Components that detach, break, or become accessible can affect the analysis. Fasteners, decorative pieces, wheels, eyes, beads, caps, and internal components may need evaluation depending on the product.
Evidence and report review
Confirm that the tested sample matches the imported product and that the report identifies the relevant methods, age category, and results. Verify the laboratory facility's accepted scope. Compare photographs and dimensions, and investigate any design or material change after testing.
Labels are not a substitute for design compliance
Where a warning applies, review its exact text, placement, prominence, permanence, and consistency with the product's intended age. A warning does not make a prohibited small part acceptable for a product intended for children under three.
Maintain change control
Changes to dimensions, material strength, attachment methods, or component suppliers can affect whether parts detach or fit within the test fixture. Route changes through compliance review before reusing evidence.
ComplyMyImport can connect product facts, report pages, label reviews, and change records. It does not make an automatic legal determination.
This guide is general educational information, not legal advice.
Official source
- CPSC small parts business guidance: cpsc.gov/Business--Manufacturing/Business-Education/Business-Guidance/Small-Parts-for-Toys-and-Childrens-Products