16 CFR 1303 lead paint: the 90 ppm limit for paint and surface coatings

Paint and surface coatings on toys and children's products are limited to 90 ppm lead. Which items it covers, how it differs from total lead in substrate, and how to cite it.

The problem

16 CFR Part 1303 bans paint and similar surface coatings with more than 0.009% (90 ppm) lead, and bans toys and children's articles that bear such paint. This is separate from the CPSIA total-lead limit (100 ppm) for substrate materials.

Typical products: painted or coated toys, kids' furniture, printed children's apparel with surface coatings, painted zippers or snaps.

What the lab tests: lead content in each paint or coating color, usually by XRF or wet chemistry per CPSC method.

Not sure the rule applies? Take the Do I need a CPC? quiz or run the free recall check for your product.

How to fix it

Confirm the rule applies to your product type and age grade (CPSC Regulatory Robot, then your lab).
Test at a CPSC-accepted lab whose accreditation scope includes 16 CFR 1303.
Cite it on the CPC exactly, e.g. 16 CFR Part 1303, and only if the report shows it was tested.
Make sure the product name, model/SKU and photos match across the report, CPC and Amazon listing.
Test every distinct paint color; a missing color is a common gap.
Cite total lead (CPSIA §101) as well if substrates are accessible.

Share your CPC in your AI

Keep your confirmed CPC, test report and compliance facts in Avenbridge. Resellers, labs and marketplace contacts can then ask about them in ChatGPT or Claude, and questions it can't answer come back to you.

Share your CPC in your AI or run the free document-vs-listing check first

Avenbridge is CertTrail's product. How to connect.

Checklist before resubmitting

16 CFR 1303 listed on the test report
Lab accepted by CPSC for this rule
Rule cited on CPC
Identifiers match listing

Sources