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Small Batch Manufacturer registration: what testing relief it does and doesn't give

Registered small batch manufacturers get relief from third-party testing for Group B rules only. Group A rules (like lead in paint and small parts) always need a CPSC-accepted lab.

The problem

CPSC lets qualifying Small Batch Manufacturers (revenue and per-product unit thresholds set by CPSC each year; at most 7,500 units of the same product in the prior year) register for relief from some third-party testing.

The relief applies only to Group B requirements. Group A requirements always need third-party testing at a CPSC-accepted lab, including lead in paint (16 CFR 1303), small parts (16 CFR 1501), pacifiers, lead in children's metal jewelry, durable infant or toddler products, and baby bouncers/walkers/jumpers. Registered small batch manufacturers still issue a CPC and include their registration number.

Note that small batch relief is generally for manufacturers; check CPSC's guidance on whether it fits your situation if you import finished goods.

How to fix it

  1. Check CPSC's current revenue and unit thresholds for the calendar year.
  2. Register in the Small Batch Manufacturers Registry before relying on relief.
  3. Identify which of your rules are Group A (must be third-party tested) vs Group B.
  4. Document the alternative compliance basis for Group B rules.
  5. Issue a CPC with your registration number.

Check your documents before you resubmit

Upload your CPC or GCC and the test report. The free pre-check compares identifiers, cited rules, lab, dates and certifier across the documents and returns a red/amber/green list of what to fix.

Run the free pre-check

Checklist before resubmitting

Sources

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.

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