Do kids' shoes need a CPC to sell in the US?
Kids' shoes need a Children's Product Certificate when they're mainly designed or intended for children aged 12 or younger. Occasional use by children doesn't decide this: assess the four factors for the particular product (16 CFR 1200.2).
Which certificate you need
Applicable children's product safety rules without a testing exemption need testing by a CPSC-accepted lab whose scope covers the rule. Component testing can be used as the law allows (16 CFR 1107).
For imported finished shoes, the US importer must issue the CPC before entry; a certificate issued by the factory doesn't replace that CPC (16 CFR 1110.7).
Since July 8, 2026, importers must electronically submit the certificate data in ACE when filing each shipment's entry, irrespective of the value of those goods (16 CFR 1110.13).
Check both the footwear lab's acceptance and its scope for the tested provisions in the CPSC directory. Verify the report number with the lab and have a report for each model and color (CPSC lab search).
Which tests apply
Accessible base materials can't exceed 100 ppm lead, subject to the statutory exceptions, including inaccessible parts (15 U.S.C. 1278a). Paint or similar surface coatings have a separate limit of 90 ppm, or 0.009% (16 CFR 1303).
A 1500.91 testing exemption depends on meeting all its conditions. Materials covered by paragraph (d) can't acquire lead through processing or added materials, and textiles can't have applications other than those made entirely of dyes. Metals must meet paragraph (e), including no intentional addition of lead; an exemption from testing doesn't remove the lead limit (16 CFR 1500.91).
Shoes containing or designed for button or coin batteries need the applicable compartment and warning tests, whether batteries are replaceable, included or sold separately, unless a specified toy or zinc-air exception applies (16 CFR 1263). The clothing flammability exclusion requires footwear not made wholly or partly of hosiery and not attached to or part of another garment (16 CFR 1610.1).
What goes on the label
As far as practicable, shoes and packaging need permanent, legible tracking marks for the manufacturer or private labeler, production place and date, and batch. Imported goods also need country-of-origin marking, subject to legal exceptions (19 CFR 134).