US import compliance — testing
CPSC testing: what to test, who tests it, and what drives the cost
Testing is where importers spend the most money and waste the most money, because labs quote what you ask for. Ask for the wrong rule set and you pay for tests your product never needed — then still get the entry held because the certificate was never issued properly.
Who has to use an accredited lab
It depends on the certificate, not the product value. A children's product needs a CPC backed by third-party testing at a CPSC-accepted laboratory — your supplier's own report, however good it looks, cannot support it. A general-use product takes a GCC, which can rest on testing from any qualified laboratory or on a reasonable testing programme the manufacturer documents.
This is the single most common paperwork failure we see: a general-use GCC supplied for a product that is in fact intended for children, where a CPC with accredited testing was required all along.
What actually drives the price
- The rule set. You pay per rule, per material. Total lead content, lead in paint, phthalates, small parts, flammability and toy safety are separate tests — a toy battery combines several.
- How many distinct materials. A bottle with one plastic body is not the same quote as one with a silicone nipple, a printed sleeve and a metal ring.
- How many variants you test as separate products. Styles that share materials and construction can be quoted as a variant matrix — shared tests run once — instead of six full batteries. Always ask for it by name.
- Retesting. A design, material or process change invalidates the testing behind the certificate. That is the recurring cost, not the first test.
And the discount most people never claim: qualifying registered small batch manufacturers may be relieved of third-party testing for some children's product rules. Check CPSC's Small Batch Manufacturer guidance before you sign a lab quote.
Retesting and periodic testing
A certificate must sit on a continuing testing programme, not on one test from years ago. CPSC's periodic testing rules set a cadence — commonly one, two or three years depending on the rule — and any material change to the product or the process triggers retesting outside that calendar. Practical rule: when the product changes, or when a rule's period rolls over, the test needs refreshing and the certificate needs reissuing.
What the lab does not give you
The lab gives you a test report. It does not file your entry, and it does not take responsibility for the certificate. You issue the CPC or GCC as the manufacturer or importer, citing each rule by number, with the manufacture date, the testing date, the laboratory, the product identity and a point of contact. Since 8 July 2026 that certificate data must also be eFiled with CBP through ACE on every shipment of a regulated product, with no de minimis exemption for low-value consignments — the $800 threshold does not apply. See how CPSC is enforcing it →
Frequently asked questions
How much does CPC testing cost?
Nobody publishes a single answer, because the price is set by the rule set, not by the product. A single-rule test on one material (lead, for example) is a small fraction of a full children's toy battery, which combines ASTM F963 physical/mechanical testing, flammability, lead in substrate and paint, and phthalates across the materials the product uses. The costs that surprise people are re-testing after a design or material change, and testing each variant as though it were a new product.
Can I avoid testing my children's product?
No for the rules themselves — a CPC has to rest on third-party testing by a CPSC-accepted laboratory. What you can legitimately reduce is the volume of testing: qualifying registered small batch manufacturers get relief from third-party testing on some children's product rules, shared materials across variants can be tested once under a variant matrix, and you only need to test the rules that actually apply to your product. Paying for rules that do not apply is the most common waste.
Do I have to retest every year?
Not automatically. The certificate has to be supported by a continuing testing programme, and CPSC's periodic testing rules set a cadence — commonly one, two or three years depending on the rule and the product. A material change to the product, the materials or the manufacturing process requires retesting regardless of the calendar, and Amazon will ask for current documents at any time.
Who is allowed to test my product?
For a children's product (a CPC), the laboratory must be CPSC-accepted — a supplier's in-house report or an unaccredited lab report will not support the certificate. For a general-use product (a GCC), any qualified laboratory, or a documented reasonable testing programme run by the manufacturer, can support the certificate.
Does the passing test report mean I am compliant?
No. The test report is evidence; the certificate is the deliverable. You issue the CPC or GCC yourself as the manufacturer or importer, citing each rule by number, and since 8 July 2026 that certificate data also has to be eFiled with CBP on every shipment. A file of PASS reports with no certificate behind it fails on the document, not on the product.
Rule data transcribed from CPSC.gov; not legal advice — review with a qualified compliance professional before testing or filing. EntryReady is operated in Australia.