CPSIA for Plush Toys: The US Importer’s Guide to Testing, CPC and eFiling (2026)

1. Does CPSIA apply to your plush?

The Consumer Product Safety Improvement Act of 2008 (CPSIA) defines a children’s product as one designed or intended primarily for children 12 years of age or younger. Plush toys almost always fall inside that definition. The Consumer Product Safety Commission (CPSC) decides intended age from the product itself: the manufacturer’s stated age, how it is packaged and marketed, where it is sold, and whether children would recognize it as meant for them. A soft, cuddly character is read as a toy, whatever the hangtag says.

Three situations cause most of the confusion for brands buying plush overseas:

2. The requirements at a glance

The table lists the federal and state requirements a typical custom plush meets before it can enter and sell in the US. Not every row applies to every design: a plush with embroidered eyes and no plastic parts has a much shorter test list than one with a vinyl face, safety eyes and a zipper pouch.

Two things follow from the table. First, the materials list decides the cost of testing: every plastic, vinyl, painted or printed component adds lab work. Second, most of the paperwork sits with the importer, while most of the evidence comes from the factory and the lab. A sourcing partner’s job is to make sure that evidence exists, matches the production and arrives before the goods do.

3. ASTM F963-23: what the lab tests on plush

ASTM F963 is the US consumer safety specification for toys. Congress made it mandatory in 2008; the CPSC adopted the 2023 revision, ASTM F963-23, as the mandatory standard from April 20, 2024 (16 CFR part 1250). Not every section is part of the mandatory third-party testing scope, and the lab decides which sections apply to a given toy. For a typical plush, the work concentrates on four areas:

Age grading drives everything else. Most plush is graded for all ages, including children under 3, which means no small parts may come loose after the use-and-abuse tests. Design choices make a measurable difference here: embroidered eyes and noses remove the torque and tension risk entirely, while plastic safety eyes need locking washers that survive the pull test, and a lab report showing they did.

4. Lead and phthalates: where plush fails

Polyester plush fabric and fiberfill rarely cause chemical failures. The risk sits in the small hard and soft components that make a design distinctive. CPSC has determined that certain materials do not exceed the lead limits, including textiles without after-treatments such as screen prints, transfers or vinyl, so a lab can often exclude plain fabric from lead testing. Everything else needs evidence.

Component testing is allowed under CPSC’s rule on component part testing (16 CFR part 1109): a certifier may rely on test results for a component, such as an eye supplier’s report, if the component is traceable to what went into the finished product. In practice that means keeping supplier reports, lot numbers and purchase records together with the production file.

5. The Children’s Product Certificate

Under section 14 of the Consumer Product Safety Act and 16 CFR part 1110, domestic manufacturers and importers of children’s products must certify, in a written Children’s Product Certificate (CPC), that the product complies with every applicable children’s product safety rule, based on test results from a third-party CPSC-accepted laboratory. For plush made in Vietnam or China, the US importer issues it. The CPC and supporting test reports must be in English. There is no required template, but there are seven required elements:

1. Product identification. Enough detail to match the certificate to each product it covers and no others: style number, description, colorways.
2. Citation of each rule. Every CPSC children’s product safety rule the product is certified to, for example 16 CFR part 1250 (ASTM F963-23), lead and phthalates.
3. The certifying party. Name, full mailing address and phone number of the importer certifying compliance.
4. Records contact. Name, address, email and phone of the person who keeps the test records.
5. Date and place of manufacture. At least month and year, and city or region and country; a street address if the manufacturer has more than one site in that city.
6. Date and place of testing. When and where the product was tested.
7. The lab. Name, address and phone number of each CPSC-accepted third-party lab that tested the product.

Element five is where sourcing changes bite. A CPC names the place of manufacture, so moving a style to a different factory, or to a different country, is not a paperwork edit. It requires testing of the product made at the new site. The guide on moving plush production from China to Vietnam covers that transition step by step.

6. eFiling: certificates at the border since July 8, 2026

Until 2026, a CPC only had to accompany the shipment and be available on request. Under the Certificates of Compliance final rule published on January 8, 2025, importers of most regulated consumer products must electronically file certificate data with US Customs and Border Protection (CBP) from July 8, 2026, through a Partner Government Agency (PGA) Message Set.

1. Who filesThe importer of record, or its customs broker.

   CPSC treats the importer of record as responsible. A broker that lacks product knowledge can identify the owner, purchaser or consignee as the party responsible for certification.

2. HowFull data in ACE, or a reference to the Product Registry.

   The certificate data can travel with each entry in CBP’s Automated Commercial Environment, or be stored once in CPSC’s Product Registry and referenced at entry. The Product Registry is set up by the importer, using its importer of record number.

3. WhenAt entry, not after.

   The data has to be ready when the entry is filed. A shipment that arrives before its certificate data exists is the shipment that waits at the port.

4. RecordsFive years.

   Certificates and the test records behind them must be kept for five years.

7. Tracking labels, warnings and state law labels

Tracking labels. CPSIA section 103 requires permanent, distinguishing marks on children’s products and their packaging, to the extent practicable, that let the manufacturer or private labeler, the location and date of production, and cohort information such as the batch or run number be identified. On plush, this information usually sits on a sewn-in fabric label, repeated on the polybag or retail packaging and the carton. A hangtag alone is not permanent.

Choking-hazard warnings. Toys intended for children aged 3 to 6 that contain small parts must carry the cautionary statement set out in 16 CFR 1500.19 on the packaging, and in online listings and catalogs where the product is sold remotely. Plush graded for all ages should have no small parts at all, so no warning applies.

Stuffed-article law labels. Pennsylvania, Ohio and Massachusetts regulate stuffed toys. Each requires the manufacturer to register, and the toy to carry a law label declaring the filling material, for example “All New Material” with the fiber content, and a registration number. Points that trip up imported plush:

• Pennsylvania registrations are tied to a specific manufacturing facility and cannot be shared or transferred between facilities. A new factory needs its own registration.
• Pennsylvania does not accept registrations issued by other states, while Ohio and Massachusetts have accepted a Pennsylvania registration number on a uniform label (Toy Association summary). Check each state’s current rules before printing labels.
• The registration must be current when the goods are sold, and is renewed annually in Pennsylvania.

Large US retailers typically require the law label on every stuffed item they buy, whichever states they sell in, so in practice most imported plush carries one.

8. Testing in practice: when, how often, what triggers a retest

The test plan follows the product’s life: before the first shipment, during long runs, and every time something material changes.

1. At inquiryDeclare every market and every retailer.

   The destination decides the test scope. A plush for the US and the EU needs a program that covers ASTM F963 and EN 71 together; adding a market after production has started can mean re-sampling and more testing.

2. SamplingFix the bill of materials.

   Fabric, fill, eyes, prints and trims are chosen with testing in mind. Component reports from suppliers are collected at this stage.

3. Pre-productionTest the approved sample and risky components.

   Testing vinyl faces, eyes and prints early catches a failure while it is still cheap to change.

4. ProductionCertify on production units.

   The certificate rests on third-party testing of samples representative of what ships. Representative-sample records are kept for five years.

5. Long runsPeriodic testing.

   If a product stays in production for more than a year, the manufacturer must run periodic third-party testing: at least once a year under a periodic testing plan, or every three years where an ISO/IEC 17025-accredited lab runs production testing (16 CFR 1107.21). Runs shorter than a year have no periodic obligation.

6. Any changeMaterial change means retest.

   A new eye supplier, a different vinyl compound, a new print ink or a new factory are material changes that require new third-party testing of the affected parts.

CPSC accepts labs for specific test scopes, and accepted labs operate in Vietnam as well as China. STC Vietnam, for example, states that its Ho Chi Minh City lab is CPSC-accepted for CPSIA and ASTM F963 testing. Always confirm a lab’s current acceptance and scope in CPSC’s lab search before relying on its reports.

9. State chemical laws and retailer requirements

Federal law sets the floor. Several states and most large retailers add requirements on top:

Higher-tier audit programs such as FAMA, BSCI and SMETA are held by a limited number of qualified facilities with higher overheads, and are generally practical for orders of relatively large quantity. For smaller runs, product-safety testing to the destination market’s standard is the right level of assurance.

10. Eight mistakes that hold up plush shipments

1. Sending an EN 71 report to a US buyer. EN 71 and ASTM F963 test different things with different methods. A European report does not cover US lead, phthalate or ASTM requirements.
2. Testing the sample, shipping something else. Certificates rest on production-representative units. If eyes, fabric or prints changed after sampling, the report no longer describes the product.
3. Forgetting the vinyl face. Vinyl-face and printed plush need phthalate testing on the plasticized parts. Plain-plush habits miss it.
4. Swapping a component mid-run. A cheaper eye or zipper supplier is a material change and needs testing before the parts go into production.
5. Listing the wrong factory on the CPC. The certificate names the place of manufacture. A style moved between factories needs testing of the new production.
6. Using another facility’s law-label number. Pennsylvania registrations belong to one facility. A label printed with the previous factory’s number is a labeling violation.
7. Missing eFiling data at entry. Since July 8, 2026, the certificate data must be filed when the entry is made. Missing data means holds and demurrage.
8. Calling a toy an adult collectible. If the design, channel and marketing say toy, CPSC treats it as one.

11. How Takara runs US compliance on a plush order

Takara is a creative-manufacturing partner, not a factory owner, and holds no certifications itself. Accredited labs test the products, partner factories hold their audit certificates, and the US importer issues the CPC. Takara’s role is to make sure all of that lines up before the goods ship:

• Specify the requirements with you at inquiry: markets, retailers, age grade, licensor rules.
• Assign a partner factory that is eligible for those requirements, including retailer or licensor audits where the volume justifies them.
• Plan component and finished-product testing at a CPSC-accepted lab into the quote and the schedule.
• Prepare tracking-label and law-label artwork with the right factory, batch and registration details.
• Hand over test reports, factory address and production dates in time for your CPC and your broker’s eFiling.

This is how Takara ran ThreeSixty Group’s Vietnam program: 120,000 plush dolls produced at a FAMA-audited partner factory and delivered to Walmart and Target. Reference terms for US orders, including the 1,000-piece export minimum per design and FOB or DDP delivery, are on the page for US brands.

Selling in more than one country? The US export checklist sits alongside guides for the EU, UK, Japan, Canada and other markets.

12. Frequently asked questions