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CPSC children'sUnited StatesStuffed toys

Do stuffed toys need a CPC?

Updated

Short answer

Yes.

CPSC's children's product rule names stuffed animals as products commonly recognized as intended for children (16 CFR 1200.2). A plush toy is also a toy, so it must meet ASTM F963-23, the mandatory toy standard in 16 CFR 1250, plus the lead and phthalate limits. You need third-party tests at a CPSC-accepted lab, a Children's Product Certificate (CPC), tracking labels, and eFiling of the CPC data with each entry.

What changes the answer

  • Age grade. Toys for children under 3 must have no small parts (16 CFR 1501), and plush toys are listed in 1501.2 as articles for that age group when so intended. Eyes, noses, buttons and seams are pulled in use-and-abuse testing.
  • Collectibles for adults. A plush sold as an adult collectible can be general use. 1200.2 contrasts collectible plush bears, with high cost, fine detail, fragile accessories and display stands, against children's bears with low cost and simple accessories. Marketing next to children's products undercuts the claim.
  • Electronics and batteries. Plush with sound modules, lights or button cells must meet the F963 battery requirements. Toys that meet the battery rules in 16 CFR 1250 are exempt from Reese's Law under 1263.1(c). Bluetooth or Wi-Fi plush also needs FCC certification.
  • Stuffing materials. Some states require registration or labeling of stuffed articles and their filling. Those are state rules on top of the federal requirements.

What to do

  1. Assign an age grade using CPSC's age determination guidelines and print it on the package.
  2. Have a CPSC-accepted lab test to the applicable sections of ASTM F963-23 (mechanical, flammability, stuffing material cleanliness, and labeling), lead content in accessible parts, lead in coatings, and phthalates in plasticized parts.
  3. Issue a CPC that lists 16 CFR 1250, 1303, the lead content limit, 16 CFR 1307 and 1501 where relevant, and eFile it with the entry as required since July 8, 2026.
  4. Add permanent tracking labels to the toy, usually on the sewn-in label, and to the packaging.
  5. Add the small parts warning required by 16 CFR 1500.19 if the toy is for ages 3 to 6 and contains small parts.
HTS lines for stuffed toys
  • 9503.00.00.71

    9503: Tricycles, scooters, pedal cars and similar wheeled toys; dolls' carriages; dolls, other toys; reduced-scale ("scale") models and similar recreational models, working or not; puzzles of all kinds; parts and accessories thereof

    "Children's products" as defined in 15 U.S.C. § 2052 / Labeled or determined by importer as intended for use by persons / Under 3 years of age

    Toys labeled or determined for children under 3.

    General rate
    Free
  • 9503.00.00.73

    9503: Tricycles, scooters, pedal cars and similar wheeled toys; dolls' carriages; dolls, other toys; reduced-scale ("scale") models and similar recreational models, working or not; puzzles of all kinds; parts and accessories thereof

    "Children's products" as defined in 15 U.S.C. § 2052 / Labeled or determined by importer as intended for use by persons / 3 to 12 years of age

    Toys labeled or determined for ages 3 to 12.

    General rate
    Free

Next steps

Frequently asked questions

Do stuffed toys need phthalate testing if they are all fabric?
Natural fibers and untreated manufactured fibers are on CPSC's list of materials that need no phthalate testing. Plastic eyes, noses, coated fabrics, vinyl parts and printed areas do need testing.
Is a plush pet toy a children's product?
Not if it is designed and marketed only for pets. CPSC looks at marketing and how consumers see the product, so a pet toy that looks and sells like a kids plush can be treated as a children's product.
What HTS age line should I use?
Use the same age grade as on the label. Under 3 goes to 9503.00.00.71 and 3 to 12 to 9503.00.00.73. The age you print also decides which CPSC rules your lab tests to.

Sources

  1. 16 CFR 1250.2, Requirements for toy safety, eCFR, National Archives
  2. 16 CFR 1200.2, Definition of children's product, eCFR, National Archives
  3. 16 CFR 1501.2, Small parts regulation scope, eCFR, National Archives
  4. Children's Products business guidance, U.S. Consumer Product Safety Commission
  5. Certificates of Compliance final rule (eFiling), published January 8, 2025, Federal Register

This is general information drawn from the official sources linked above. It is not legal advice. Rules change and often turn on the facts of your product, so confirm your test plan with an accredited lab and your obligations with qualified counsel before you import or sell.