Product InspectionThird-party testing for children's products: accepted laboratories, material changes and periodic testing
Sources checked
Federal law requires that every children's product be tested by a third-party, CPSC-accepted laboratory for compliance with the applicable federal children's product safety requirements, according to CPSC's Third Party Testing Guidance page. That page also states that if material changes are made to a children's product after initial certification, the finished product or the component part that was changed must be retested for compliance with those rules affected by the material change. For products in continuous manufacture, 16 CFR § 1107.21 requires periodic testing.
What counts as a CPSC-accepted laboratory
The Lab Accreditation page defines third-party testing as "testing performed by a third-party accredited laboratory that CPSC has accepted to perform the specific tests for each children's product safety rule."
The regulation text uses its own term. 16 CFR 1107.2 defines a third party conformity assessment body as "a testing laboratory whose accreditation has been accepted by the CPSC to conduct certification testing on children's products," and adds that "Only third party conformity assessment bodies whose scope of accreditation includes the applicable required tests can be used for children's product certification or periodic testing purposes."
The Third Party Testing Guidance page reports that CPSC has accepted more than 600 laboratories worldwide to perform testing for a variety of requirements for children's products. The same page notes that because accreditation is rule-specific, not all laboratories can conduct all applicable testing, and firms may be required to use more than one laboratory to perform all of the required testing for a particular product.
The list itself lives on the List of CPSC-Accepted Testing Laboratories page, which states that section 14(a)(3)(E) of the Consumer Product Safety Act, as amended, requires the Commission to "maintain on its Internet website an up-to-date list of entities that have been accredited to assess conformity with children's product safety rules." That page also states that a manufacturer of a children's product that must comply with one or more of these rules must support its certification of compliance with test results from one of these laboratories.
Testing for certification
16 CFR 1107.20(a) requires that manufacturers "submit a sufficient number of samples of a children's product, or samples that are identical in all material respects to the children's product, to a third party conformity assessment body for testing to support certification."
Component part testing has a defined place in this. 16 CFR 1107.20(c) provides that, except where otherwise specified by a children's product safety rule, component part testing pursuant to 16 CFR part 1109 may be used to support the certification testing requirements of that section. The Third Party Testing Guidance page says the specifics of conditions and requirements for component part testing, which includes composite testing, are codified at 16 CFR part 1109.
Failures are handled individually. Under 16 CFR 1107.20(d), if a product sample fails certification testing to the applicable children's product safety rule(s), even if other samples have passed the same certification test, the manufacturer must investigate the reasons for the failure and take the necessary steps to address them.
Material changes
16 CFR 1107.2 defines the term: "Material change means any change in the product's design, manufacturing process, or sourcing of component parts that a manufacturer exercising due care knows, or should know, could affect the product's ability to comply with the applicable rules, bans, standards, or regulations."
The consequence follows in 16 CFR 1107.23(a), whose first sentence provides that if a children's product undergoes a material change in product design or manufacturing process, including the sourcing of component parts, which a manufacturer exercising due care knows, or should know, could affect the product's ability to comply with the applicable children's product safety rules, the manufacturer must submit a sufficient number of samples of the materially changed children's product for testing by a third party conformity assessment body and issue a new Children's Product Certificate.
What counts as a change is spelled out in the last sentence of 16 CFR 1107.23(d): "This includes, but is not limited to, changes in component part composition, component part supplier, or the use of a different component part from the same supplier who provided the initial component part."
The Third Party Testing Guidance page states the same outcome in plain terms: the finished product or the component part that was changed must be retested for compliance with those rules affected by the material change.
Periodic testing
16 CFR 1107.21(a) states that all manufacturers of children's products must conduct periodic testing, and that all periodic testing must be conducted by a third party conformity assessment body. The same paragraph states that periodic testing must be conducted pursuant to either paragraph (b), (c), or (d) of that section or as provided in regulations under that title.
The Third Party Testing Guidance page points to § 1107.21 as the requirement for periodic testing for children's products that are in continuous manufacture.
Under 16 CFR 1107.21(b), a manufacturer must conduct periodic testing to ensure compliance with the applicable children's product safety rules at least once a year, except as otherwise provided in paragraphs (c) and (d) of that section or as provided in regulations under that title.
| Rule | Interval | Condition |
|---|---|---|
| 16 CFR 1107.21(b) | At least once a year | Except as otherwise provided in paragraphs (c) and (d) of that section, or as provided in regulations under that title |
| 16 CFR 1107.21(d)(1) | At least once every three years | For manufacturers conducting testing to ensure continued compliance with the applicable children's product safety rules using a testing laboratory accredited to ISO/IEC 17025, "General requirements for the competence of testing and calibration laboratories" |
Two further requirements sit around the interval. 16 CFR 1107.21(b)(1) requires manufacturers to develop a periodic testing plan to ensure with a high degree of assurance that children's products manufactured after the issuance of a Children's Product Certificate, or since the previous periodic testing was conducted, continue to comply with all applicable children's product safety rules. And 16 CFR 1107.21(f) requires a manufacturer to select representative product samples to be submitted to the third party conformity assessment body for periodic testing.
Other duties in part 1107
16 CFR 1107.24(a) requires each manufacturer to establish procedures to safeguard against the exercise of undue influence by a manufacturer on a third party conformity assessment body.
On documentation, 16 CFR 1107.26(b) provides that a manufacturer must maintain the records specified in paragraph (a) of that section for five years.
Which rules need third-party testing
CPSC's Rules Requiring Third-Party Testing and a Children's Product Certificate page states that its list is complete as of December 5, 2024, and that an up-to-date list for rules requiring third-party testing is codified at 16 CFR § 1112.15.
That page also notes one carve-out: qualifying and registered small batch manufacturers (SBM) may be able to receive relief from third party testing to certain safety rules (Group B requirements), and registered SBMs may certify to Group B requirements via means other than testing by third-party, CPSC-accepted laboratories.
Questions people ask
Has CPSC accepted a laboratory that can run every test I need?
Not necessarily. The Third Party Testing Guidance page states that because accreditation is rule-specific, not all laboratories can conduct all applicable testing, and that firms may be required to use more than one laboratory to perform all of the required testing for a particular product. 16 CFR 1107.2 adds that only third party conformity assessment bodies whose scope of accreditation includes the applicable required tests can be used.
Do I have to retest the whole product after a material change?
16 CFR 1107.23(a) requires samples of the materially changed children's product to be submitted for testing by a third party conformity assessment body and a new Children's Product Certificate to be issued. The Third Party Testing Guidance page states that the finished product or the component part that was changed must be retested for compliance with those rules affected by the material change.
How often does periodic testing happen?
At least once a year under 16 CFR 1107.21(b), with the exceptions in paragraphs (c) and (d) of that section, and at least once every three years under 16 CFR 1107.21(d)(1) for manufacturers using an ISO/IEC 17025-accredited testing laboratory as described there.
Sources
- Third Party Testing Guidance, U.S. Consumer Product Safety Commission
- Third-Party Testing Laboratory Accreditation & Small Entity Compliance Guide, U.S. Consumer Product Safety Commission
- List of CPSC-Accepted Testing Laboratories, U.S. Consumer Product Safety Commission
- Rules Requiring Third-Party Testing and a Children's Product Certificate, U.S. Consumer Product Safety Commission
- PART 1107—TESTING AND LABELING PERTAINING TO PRODUCT CERTIFICATION, eCFR (Office of the Federal Register / GPO)
Checked 11 October 2026. This page is an unofficial summary and is not affiliated with the U.S. Consumer Product Safety Commission; the official text governs.