Do all plasticized components found in children’s toys and child care articles need to be third-party tested? Shoes and socks are not considered to be children’s toys or child care articles. Manufacturers, importers, and private labelers of children’s toys and child care articles must comply with the prohibition on children’s toys and child care articles containing certain phthalates by testing their products at a CPSC-accepted laboratory. Third-party testing is required for all plasticized parts in a children’s toy or child care article but is not required for certain materials known not to contain phthalates, including, but not limited to, Engineered wood products made from particleboard, hardwood plywood, or medium-density fiberboard see 16 CFR §1252.3c, and Unfinished manufactured fibers that are untreated and unadulterated-polyester polyethylene terephthalate, PET; nylon; polyurethane spandex; viscose-rayon; acrylic and modacrylic; and natural rubber latex See 16 CFR §1253.2c.
To the extent that a children’s toy kazi toy or child care article is required to be the third party tested for phthalates, you can rely upon the test results or a certification from a part supplier if the requirements in our regulation at 16 CFR part 1109 are met. For products that require phthalates testing, the manufacturer, private labeler, or importer also must issue a Children’s Product Certificate in which it certifies that the children’s toy or child care article complies with the prohibition on phthalates. Generally, certifications of a part must satisfy the requirement for a children’s product certificate. They must be based on testing results from a laboratory whose accreditation has been accepted by the CPSC.
However, if the packaging is intended to be reused, used in conjunction with a child care article, or with a children’s toy while playing, such as a heavy-gauge reusable bag used to hold blocks, it would be subject to the prohibition on phthalates. Does the prohibition on phthalates apply to children’s shoes or socks? Third-party testing is also not required for inaccessible parts of a children’s toy or child care article or products made of the following seven 7 plastics with specified additives listed in 16 CFR §1308.2: polypropylene PP, polyethylene PE, high-impact polystyrene HIPS, acrylonitrile butadiene styrene ABS, general-purpose polystyrene GPPS, medium-impact polystyrene MIPS, and super-high-impact polystyrene SHIPS. Packaging is generally not intended for use by children when they play, given that most packaging is discarded and is not used or played with as a children’s toy or child care article.