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CPSC children'sUnited StatesChildren's jewelry

Does children's jewelry need a CPC?

Updated

Short answer

Yes, when it is made or marketed for kids.

Jewelry designed or intended primarily for children 12 and under is a children's product. It must stay within the 100 ppm total lead limit for accessible parts and 90 ppm for paint and coatings, be tested at a CPSC-accepted lab, carry tracking information, and ship with a Children's Product Certificate (CPC) that is eFiled with the entry.

What changes the answer

  • What makes it kids jewelry. 16 CFR 1200.2 lists size, very low cost, play value, childish themes, and sale with children's clothing, books, toys, party favors, snacks or in vending machines. Packaging, dexterity needed to wear it and licensing also count.
  • Materials exempt from testing. Precious gemstones, many semiprecious stones, pearls, wood, untreated textiles and surgical and stainless steel, 10 karat or higher gold, sterling silver and other listed precious metals are determined not to exceed the lead limit under 16 CFR 1500.91. The determination does not cover plated base metal, glass or crystal with lead content, or paints and coatings.
  • Play jewelry and dress-up sets. Jewelry sold as a toy, with play value, falls under the toy standard ASTM F963-23 in 16 CFR 1250, and the phthalate limits in 16 CFR 1307 for plasticized parts.
  • Age under 3. Jewelry for children under 3 is subject to the small parts ban in 16 CFR 1501.
  • Cadmium. There is no federal mandatory cadmium limit in a CPSC rule for children's jewelry. ASTM F2923 is a voluntary standard, and several states set their own cadmium limits, so retailers often ask for cadmium results as well.

What to do

  1. Record why the piece is or is not a children's product under the 1200.2 factors.
  2. Test each accessible component at a CPSC-accepted lab for total lead, plus lead in any paint or coating. Clasps, jump rings, chain and charms count as separate components.
  3. Add F963, phthalate and small parts testing when the jewelry is a toy or for children under 3.
  4. Issue a CPC and eFile its data with the entry, as required since July 8, 2026. Put tracking information on the product or, where that is not practicable, on the card or package.
  5. Ask suppliers for alloy declarations and retest on any change in plating or base metal.
HTS lines for children's jewelry
  • 7117.19.90.00

    7117: Imitation jewelry

    Of base metal, whether or not plated with precious metal / Other

    Imitation jewelry of base metal, other.

    General rate
    11%
    Free or reduced under 17 programs
  • 7117.90.75.00

    7117: Imitation jewelry

    Valued over 20 cents per dozen pieces or parts / Of plastics

    Imitation jewelry of plastics valued over 20 cents per dozen pieces.

    General rate
    Free
  • 7117.90.60.00

    7117: Imitation jewelry

    Valued over 20 cents per dozen pieces or parts / Toy jewelry (except parts) valued not over 8 cents per piece

    Toy jewelry valued not over 8 cents per piece.

    General rate
    Free

Next steps

Frequently asked questions

Is a charm bracelet sold to teens a children's product?
It depends on the factors in 16 CFR 1200.2. Teen-oriented design, adult sizing and pricing point to general use. Low price, cartoon charms and sale in kids departments point to a children's product.
Is stainless steel jewelry exempt from lead testing?
Surgical steel and stainless steels in the UNS S13800 to S66286 range, except 303Pb, are listed in 16 CFR 1500.91(e), provided no lead is added. The listing does not cover base metal in plating, clad or fill, or solder, and paint still needs coating tests.
Does Prop 65 also apply?
Yes, if you sell in California and have 10 or more employees. California also has its own lead limits for jewelry, so check state rules separately.

Sources

  1. 16 CFR 1200.2, Definition of children's product, eCFR, National Archives
  2. 16 CFR 1500.91, Lead content determinations, eCFR, National Archives
  3. 16 CFR 1303.1, Lead-containing paint ban, 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.