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16 CFR 1501 small parts: choking-hazard rule for toys under 3

Toys and articles for children under 3 must not contain or release small parts (use-and-abuse tested). What it covers and how to cite it on a CPC.

The problem

16 CFR Part 1501 sets the method for finding small parts that could choke a child under 3. Toys and other articles meant for children under 3 years may not be small parts or release them after use-and-abuse testing (16 CFR 1500.18(a)(9)).

Typical products: rattles, teethers, plush toys, baby books, stacking and pull toys for 0–36 months.

What the lab tests: use-and-abuse testing (drop, torque, tension), then a small-parts cylinder check of the toy and anything that comes off.

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

1. Confirm the rule applies to your product type and age grade (CPSC Regulatory Robot, then your lab).
2. Test at a CPSC-accepted lab whose accreditation scope includes 16 CFR 1501.
3. Cite it on the CPC exactly, e.g. 16 CFR Part 1501, and only if the report shows it was tested.
4. Make sure the product name, model/SKU and photos match across the report, CPC and Amazon listing.
5. If the toy is for 3+, check the separate small-parts warning label requirements (16 CFR 1500.19) instead.

Checklist before resubmitting

• 16 CFR 1501 listed on the test report
• Lab accepted by CPSC for this rule
• Rule cited on CPC
• Identifiers match listing

Sources

• eCFR: 16 CFR Part 1501 (16 CFR 1501 small parts)
• CPSC: Accepted laboratory search
• CPSC: Regulatory Robot

This is general information and a document consistency check only. It is not certification, testing, or legal advice, and it cannot guarantee acceptance by Amazon, CPSC or CBP.

Related guides

• 16 CFR 1250 / ASTM F963: the toy safety standard Amazon expects on toy CPCs
• Amazon rejected your Children's Product Certificate (CPC): common reasons and fixes
• CPSC eFiling and certificate data elements: what your CPC or GCC must include