Safely in Their Hands: U.S. Stuffed Toy Regulations and Labeling Requirements
"Often times, promotional products, which are intended for use by adults and are given out at tradeshows and in workplaces, end up in the hands of children." -- Promotional Products Association International
You may wonder - why would the Promotional Products Association International concern themselves with toy safety? It’s true that the PPAI’s focus is on promotional products designed for trade shows, but that product category is very wide, and often includes stuffed animals and plush toys. The PPAI understand that in real life, a stuffed item which might begin as an expo giveaway will most likely end up in the hands of a child. Thus, they put product safety first and foremost, and aim to raise awareness about the safety standards for ALL products, even those not necessarily intended for children.
According to the United States Consumer Product Safety Commission (CPSC), whether or not an item is 'intended' for children's use, it must be regulated as such if foreseeable use dictates that the product's interaction with children is likely. This is further proof that children's safety is every industry's concern. The likelihood that any product eventually funnels down to small children is too great to ignore.
General areas of concern for stuffed toys include potential separation of small parts, like animal eyes, which can be a choking hazard. Construction integrity (like seam strength), chemical contents of the stuffed toy and its flammability potential are also concerns great enough to require mandatory safety testing in virtually every market, including the United States.
Beyond initial compliance tests and certification, the CPSC can request follow-up product compliance and they recommend that toy manufacturers implement a comprehensive testing strategy and establish manufacturing quality controls, such as frequent factory-line inspections.
Now, the questions you’re asking yourself may be: As a stuffed toy manufacturer or importer into the U.S., what are my testing and certification obligations? How can I maintain compliance for as long as I manufacture my children's toys and products?
Read on to get your answers, as we we overview the general requirements for stuffed toy testing and labeling, and best practices that will help you ensure continued compliance in the U.S. market.
Stuffed Toy Testing Specifications
ASTM F963 is the standard that covers all toys entering the U.S. market, and it has been a model for international standards. All toys and children's products must comply with a series of mechanical, chemical and flammability specifications detailed in this regulation. Safety requirements specific to "Stuffed and Beanbag-Type Toys" are explained in ASTM F963-17 (4.27).
Mechanical Testing ASTM F963
Mechanical tests for children's toys are designed to simulate foreseeable use wear and tear on the item through actions like throwing, pulling and dropping; and the severity of the testing is determined by the intended age of the child. Specifically for stuffed toys, testing procedures include bite tests; drop, torque, tension, and compression tests; seam strength tests; washability tests; material quality checks and strength tests on cords and elastic parts.
Small parts testing is one of the most important aspects of mechanical testing overall, as the likelihood of a separated piece of the toy can become a serious choking hazard.
Chemical Testing ASTM F963
Chemical testing is mandatory to determine the soluble migration levels of eight different heavy metals within accessible (for mouthing, sucking and ingestion) stuffed toy surface coatings and substrates. Those eight metals are: antimony, arsenic, barium, cadmium, chromium, lead, mercury and selenium -- all of which have been found to cause long-term health effects when absorbed or ingested into children's bodies.
For stuffed animals which include plastic components, additional phthalate testing is required.
Flammability ASTM F963
Flammability for solids within a stuffed toy must be tested against 16 CFR 1500.44, which is an open flame/candle test. The acceptable burn rate is less than or equal to 0.1 square inches. Non-removable clothing sewn onto the toy is tested as part of the product itself, and any removable textile fabric must undergo separate testing.
Stuffed Toy Labeling Requirements
All stuffed animals and plush toys sold in the U.S. must feature the following information on a permanently affixed tracking label:
- Manufacturer or private labeler name;
- Location and date of production of the product;
- Detailed information on the manufacturing process, such as a batch or run number, or other identifying characteristics; and
- Any other information to facilitate ascertaining the specific source of the product.
Tracking label information should be visible and legible.
Along with national labeling requirements, some states have individual state-wide labeling mandates and/or registration requirements which you should become familiar with before attempting to market in that state. For example, Pennsylvania, Massachusetts and Ohio require stuffed toy manufacturers to register with the state and submit information and examples of toy filler content for pre-approval. Once approved, the state will issue a license number which must be shown on the label.
California Prop 65 requires any product, including children's toys, to carry warning labels about significant amounts of chemicals from a list of over 900 titles).
Additional specifications and labeling requirements can be found in ASTM F963 for battery-operated plush toys. For example:
- Battery compartments must be permanently labeled to show the correct battery orientation, polarity and size of the battery;
- Batteries must comply with the mercury content requirement per various state legislation and United States public law.
Children's Product Certificate (CPC)
Once a stuffed toy product has been proven compliant by a CPSC-certified laboratory, the relevant company must provide a Child Product License (CPC) for each shipment prior to delivery to the retailer, as required by the CPSC, and also to the CPSC.
The CPC needs to include the following information:
- Detailed product description
- Each CPSC safety requirement required by the certificate
- Manufacturer or importer information
- Contact information of the test result maintainer
- Product origin
- Any third-party CPSC authorized laboratory information used in the certification process
For more details and examples of CPC, please visit the CPSC website.
Upholding Consistent Manufacturing Practices
Congratulations! Your adorable and cuddly stuffed toy has cleared all the safety testing and labeling hurdles, has entered the U.S. market and become a massive hit with children. At this point, your goal is to maintain those quality production and safety standards consistently through every batch. When factory production is constant -- and constantly out of your sight -- your toy products are vulnerable to quality variations when not routinely monitored by skilled factory-line inspectors who can catch production issues before they leave the factory floor.
Along with providing CPSC-certified lab testing assurance for your initial production batch, QIMA offers factory-line inspection at every stage of production, from initial production check to pre-shipment and labeling inspections, so your product consistently meets all national, international and even state compliance requirements.
You feel confident that your stuffed toy design will delight children, and you want to feel equally as confident that it will be a safe play partner for as long as it’s in their hands. QIMA lab testing and inspection services can meet your safety goals with safety assurance.
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