Guides

Lead testing for children's products: 100 ppm substrate and 90 ppm paint limits

Accessible components of children's products are limited to 100 ppm total lead, and paints and surface coatings to 90 ppm. How to make sure your test report covers both.

The problem

CPSC requires that accessible component parts of children's products not exceed 100 ppm total lead content (substrate materials such as metals and plastics), and that paint and similar surface coatings not exceed 90 ppm (16 CFR part 1303). Both require testing by a CPSC-accepted lab, unless a material is covered by a CPSC determination (e.g., certain unadulterated natural materials).

A common reason for a rejected CPC package is that the report covers lead in substrate but not paint (or vice versa), or that the lab isn't accepted for the specific lead test method cited.

How to fix it

1. List painted/coated parts and uncoated substrates separately.
2. Request both total lead content and lead in paint testing where both exist.
3. Cite each rule on the CPC (e.g., CPSIA section 101 lead content, 16 CFR 1303).
4. Check the lab's CPSC scope includes the test methods used.

Checklist before resubmitting

• Substrate lead tested (≤100 ppm)
• Paint/coatings tested (≤90 ppm)
• Both cited on CPC
• Lab scope verified

Sources

• CPSC: Total lead content business guidance
• CPSC: Regulatory Robot
• CPSC: Accepted laboratory search

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

• Phthalates testing for children's toys: when it applies and which materials are excluded
• Is your test lab CPSC-accepted for the rules on your CPC?
• CPSC eFiling and certificate data elements: what your CPC or GCC must include