Does a pair of cotton baby shoes need a CPC to sell in the US?
Yes, a pair of cotton baby shoes needs a Children's Product Certificate (CPC) for this category.
The things you must have
- Children's Product Certificate (CPC)
You issue this yourself, based on lab tests for the rules that apply.
- Tracking label
Ask your factory for product and packaging tracking marks.
- Country of origin marking
Your factory supplies English markings.
How many requirements are in the checklist?
The full checklist has 11 items: 4 apply to every product in this category, 4 apply only in some situations, and 3 are notes rather than steps.
Laboratory tests and their conditions
Test for lead in the base material of accessible parts when the rule applies and there is no valid legal basis for a testing exemption. Test coating lead if there is paint or a similar surface coating. For products that contain or are designed to use button or coin batteries and are not excepted under 1263.1(c)/(d), test the 1263 battery compartment and warning requirements. Check every condition of a 1500.91 testing exemption. A testing exemption does not remove the limits.
This checklist doesn't list any mandatory laboratory tests for this product.
What to look at for this product
If your pair of cotton baby shoes has accessible fabric and fastening parts, you'll need lead testing evidence for materials without a valid testing exemption.
If your shoes have painted or similarly coated decorations, ask for coating lead results covering those finishes on the shoes.
If your shoes use materials claimed to be exempt from lead testing, ask which material treatments support that exemption decision.
If your shoes have applicable safety rules without a testing exemption, you'll need a report from a CPSC accepted laboratory covering those rules.
If your shoes are being packed for import, check the permanent tracking artwork on the shoes and packaging against the production batch.
If your shoes will be imported for retail sale, check the origin artwork against the manufacturing country supplying the complete shoes with their attached fastenings.
Labels and state rules
As far as practical, put permanent, readable tracking marks on the shoes and packaging, including the manufacturer or private labeler, production location and date, batch and other details. Imported goods need country-of-origin marking under 19 CFR 134; check legal exceptions separately.
Proposition 65 lead settlements for shoes, bags and belts: coatings 90 / PVC 200 / other materials 300 ppm. These can serve as industry reference points.
How this page was prepared
This page matches a product name to the rule library. We haven't inspected the physical product, and this isn't legal advice.