What do I do when importing?

Importing products, particularly children's products.
Written by Misty Henry
Updated 4 months ago

As with any business model, there is a bit of research to do before bringing products into the US.

For many mundane items for general use or adults (people over 12y), there likely isn't much to be done outside of labeling. This labeling is, at minimum, the country of origin ("Made in"), but may also include your business name and fiber content (see the Federal Trade Commission in the Agency Resources section below).

Adult clothing follows Flammability of Wearing Apparel testing and care information labeling in addition to the labeling mentioned above. Read more about adult clothing [here].

For some more intricate general use items, food/drink containers, cosmetics, electronics, furniture, etc., there will be additional testing, certification, and labeling requirements. Because I am not familiar with those, I'll refer you the Consumer Product Safety Commission's pages for [Manufacturing], [Regulations] and [Other Agencies].


Children's Products

If you are importing a product for people under 12y, there will be some requirements for testing, certification, and labeling as well.

Age Grading

First, you need to assess the age grading of your product. If it is for children under 3y, it requires Small Parts testing at a CPSC-accepted lab [lab search here].

If the product is for children over 3y, but under 6y, it may need a small parts warning label if it includes any small parts or could create small parts during rough use [warning requirements here].

Testing

Once you have figured the age grading for your product, it's time to determine what testing, if any, it requires.

General childrens product: Total Lead Content, Lead in Surface Coatings

Clothing: Total Lead Content, Lead in Surface Coatings, Flammability of Wearing Apparel, Flammability of Children's Sleepwear

Child care article for children under 3y: Total Lead Content, Lead in Surface Coatings, Small Parts, Phthalates

Toys: Total Lead Content, Lead in Surface Coatings, Small Parts (for under 3y), ASTM F963 (including Heavy Elements), Phthalates (for under 8y)

Your product may not need any lab testing if it is exempt and/or if your manufacturer can provide authentic and up-to-date (no more than 1 year old) CPSC-accepted lab reports. More specifics on initial testing, component part testing, and frequency of testing are available [here].

  • Total Lead Content has many exemptions [here] (Note that leather must not be treated or tanned in order to be exempt)
  • Lead in Surface Coatings only applies to paints and similar coatings that can be scratched off (this includes colored zipper pulls for example)
  • Flammability of Wearing Apparel has some exemptions [here]
  • Flammability of Children's Sleepwear has tight-fitting exemptions for sizes 0-6X and 7-14 [here & here]
  • Small Parts only applies to products for children under 3y
  • ASTM F963 is for all toys, Flammability section not required
  • Heavy Elements (this is part of the ASTM F963 requirement) applies to all toys for children under 8y
  • Phthalates only applies to products that are plastic or have a plasticizer (silicone included)

Certification

After testing (and/or finding exemptions), it's time to create your official, self-certifying document. The Children's Product Certificate is required for all children's products regardless of being completely exempt from testing or not.

This document is created for every new batch of products and should be included in each shipment. While it is not a requirement to have it with each shipment, it does help make shipments move more quickly through Customs ports. You do not need to include a copy of test reports; keep that in your records and supply them upon request from the Customs agents.

The CPSC has a page and a few videos (linked on that page) to help in creating your certificate [here]. I can help create them for you [here].

Labeling

Finally, there are labeling requirements from multiple agencies depending on the product.

  • Customs will require country of origin labeling.
  • Federal Trade Commission focuses on importer identity, location of making, and fiber content (and care information for clothing).
  • Consumer Product Safety Commission requires importer identity, location of making, date of making, unique code used to track the product, and other information to ascertain the specific source of the product.

I go into more detail about labeling [here].

Would you like someone to take over creation of your Children's Product Certificates for each purchase order? I can get them prepped and ready for every shipment as you need them while also offering design consulting to make sure you always have any testing you might need covered before production. Get a retainer [here] spot.


Links to Agency Resources

- Federal Trade Commission: What is the required labeling for products?, Clothing care information
- Customers & Border Protection: Country of origin markings
- Consumer Product Safety Commission: Tracking Label, Children's Product Certificate, Testing, Product Req Robot


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