US Toy Safety Requirements for Plush: ASTM F963, CPSIA and CPC Explained

If you sell plush toys in the United States, safety compliance isn’t optional and it isn’t the factory’s job. US law puts the responsibility on the company that imports the product. This guide explains, in plain English, what the rules are and how they apply to plush and soft toys.

This guide is general information, not legal advice. Requirements change, so always confirm the current rules for your specific product with a qualified lab or compliance professional.

Is your plush a “children’s product”?

Under the Consumer Product Safety Improvement Act (CPSIA), a children’s product is one designed or intended primarily for children 12 years old or younger. The Consumer Product Safety Commission (CPSC) looks at how the product is designed, marketed, packaged and sold, not just what the label says.

In practice, almost every plush toy is a children’s product. Soft, cuddly and colourful items are generally treated as toys. The rest of this guide assumes your plush is a children’s product.

The core requirements at a glance

Requirement	What it means for plush
ASTM F963	The mandatory US toy safety standard. Covers mechanical hazards, stuffing, flammability, heavy metals, labelling and more.
Third-party testing	Testing must be done by a CPSC-accepted laboratory, not the factory’s own lab.
Lead limits	Lead in the material (substrate) and in paint or surface coatings must be under federal limits.
Phthalates	Plasticised parts (vinyl eyes, noses, tags) must be below limits for restricted phthalates.
Small parts	Toys for children under 3 must not contain or release parts small enough to be a choking hazard.
Children’s Product Certificate (CPC)	A certificate issued by the importer, based on passing test results.
Tracking labels	Permanent marks on the product and packaging identifying the source, date and batch.
Country-of-origin marking	“Made in China” (or the relevant country), legible and permanent.

ASTM F963: what gets tested on a plush toy

ASTM F963 is the Standard Consumer Safety Specification for Toy Safety. It is incorporated into federal law as a mandatory standard, and the CPSC updates the referenced edition from time to time. For plush, the most relevant sections are:

• Use and abuse testing. The lab simulates a child pulling, twisting, dropping and biting the toy. Eyes, noses, ribbons and appendages are subjected to torque and tension tests, then checked for small parts, sharp points and sharp edges.
• Seam strength. Seams must not open under test to expose fill or small components.
• Stuffing materials. Fill must be clean and free of objectionable matter such as insects, dirt or sharp foreign objects.
• Small parts. For toys intended for children under three, no part (before or after abuse testing) may fit inside the small-parts test cylinder.
• Flammability. Textile materials must not burn faster than the permitted rate.
• Heavy metals. Accessible surface coatings and substrates are tested for soluble heavy metals.
• Cords, straps and elastics. Length and loop limits apply, especially for toys for younger children.
• Age grading and warnings. The toy must carry the correct age grading, plus any required cautionary labelling.

Some product types trigger additional rules. Infant rattles, for example, have their own dimensional requirements, and teethers and toys with batteries, magnets or sound modules have extra tests.

Designing to pass

The best time to think about compliance is before the first sample. A few common decisions make a big difference:

• Embroidered eyes are the simplest route for toys aimed at babies and toddlers. Plastic safety eyes can pass for under-3s, but they must be secured with a proper locking washer and survive torque and tension tests.
• Pellets or beads used for weight must be sealed inside an inner bag, so they can’t escape if a seam fails.
• Removable accessories such as hats, bows and clothing should be sized or attached so they don’t become small parts.
• Ribbons and cords need to stay within length limits.
• Squeakers and rattle inserts must be enclosed so they can’t be reached after seam or abuse testing.

Third-party testing

Children’s products must be tested by a CPSC-accepted third-party laboratory. The CPSC publishes a searchable list of accepted labs and the tests each is accredited for. A factory’s in-house test report does not meet this requirement, however professional it looks.

Testing is normally done on production samples, or on samples made from production materials, so the results reflect what you are actually selling. Material changes, such as a new fabric supplier or a different eye component, can require re-testing.

The Children’s Product Certificate (CPC)

The CPC is a document in which the importer certifies that the product complies with all applicable children’s product safety rules, based on passing third-party tests. It must include:

1. Identification of the product
2. Each safety regulation the product is certified to
3. Identification of the importer or domestic manufacturer certifying the product
4. Contact details for the person who maintains the test records
5. Date and place of manufacture
6. Date and place of testing
7. Identification of the third-party lab(s)

The CPC must accompany the product and be available to your retailers and distributors, and to the CPSC and US Customs on request. The CPSC has also introduced requirements to file certificate data electronically at the time of import.

Tracking labels

CPSIA requires children’s products and their packaging to carry permanent tracking information, to the extent practicable. It must allow you and your customers to identify:

• The manufacturer or private labeller
• Where and when the product was made
• Batch, run or other identifying production information

For plush, this is usually printed on a sewn-in fabric label and on the packaging or hang tag. The information has to survive the product’s normal life, so a paper sticker isn’t enough on the toy itself.

Country-of-origin marking

US Customs requires imported goods to be marked with their country of origin in English, in a conspicuous place, as legibly and permanently as the article allows. For plush made in China, “Made in China” on the sewn-in label and on the retail packaging is standard.

State requirements

Federal rules are the baseline. Some states add their own:

• Stuffed-toy laws. A small number of states regulate new stuffed articles and may require a registration number and a sewn-in “law label” listing the filling materials.
• Chemical disclosure. California’s Proposition 65, and chemical reporting laws in states such as Washington, Oregon, Vermont and Maine, can apply to children’s products.

We check which state requirements apply based on where you sell.

Retailer and licensor requirements

Major retailers and licensors often go further than the law. They may require specific labs, additional tests, social-compliance and quality audits of the factory, and their own inspection protocols. If you are selling into a big-box retailer or producing under a licence, share their vendor manual with us early. It affects factory choice and testing plans.

Who is responsible?

Under US law, the importer of a children’s product is responsible for certifying it. If you buy directly from an overseas factory and import the goods yourself, that responsibility is yours, including if there is a recall.

When Meridian acts as importer of record, we take on that role: we arrange the testing, issue the CPC, make sure labels and marking are correct, and hold the documentation.

Next steps

Planning a plush toy for the US market? Talk to us about your product and the retailers you are selling to, and we’ll map out the testing and labelling it needs. For materials that make testing easier, see our guide to plush materials.