Children's Products: How Often To CPSIA Test Samples Without It Costing A Fortune?To answer this question we’ll use the example of a company that is producing products that need to adhere to the CPSIA test requirements commonly required for toys and children’s products by the Consumer Product Safety Commission of the USA.

As you may know, this type of third-party lab testing is something you have to do (unless the manufacturer does it all themselves, which is quite unlikely) and it can get expensive quickly. So how do you choose how frequently to repeat the tests during ongoing production in order to assure compliance, but without doing it so often that the costs become too onerous?


The Situation

You’re manufacturing children’s products in China.

You have sent prototypes to be CPSIA tested by a CPSC-accredited third-party lab and they have passed.

Now, you’re going into mass production and you’re wondering:

  • How often do samples need to be sent for lab-testing during production?
  • How many samples need to be chosen at random for this testing?
  • Will this vary for different product categories?


Our suggestions

Our suggestions for this scenario are as follows:

Devising your testing plan

A “reasonable” testing plan depends on how much confidence you have in the stability of everything that comes into the products you are buying from your whole supply chain: the materials & components (and how they are processed), the fabrication & assembly processes of your direct supplier, etc, and that includes the methods followed, the equipment used, and so forth.

It also depends on how much risk you can tolerate and on the tests that are most important vs less important (even though all may be compulsory, you might want to test only some of them on any given batch in order to reduce costs).

Lab-testing some samples from the first production batch

There is usually a big gap between the pre-production samples (or ‘prototypes’) and the first production’s samples (different equipment, methods…). So, it is prudent to do some testing on the first production batch in case they do vary from the samples that initially passed.

And keep in mind, it’s not just about lab tests:

  • You also need to make sure your QC inspection checklist includes all the points that your inspectors can check. Sometimes that means they have to use the factory’s testing equipment.
  • Your factory may have to run some tests on their own, without your inspectors. Make sure they report those data to you, as it can’t hurt and can only help you. 

These 2 sources of data (your own inspections, and your factory’s testing) are part of your quality assurance approach. They help reduce risks.

How often to select samples for testing?

After the first batch, you probably need to set up a randomized testing program, so that the supplier doesn’t know when you will pick samples for testing and doesn’t know what tests you will follow. This will keep them on their toes.


Do you currently CPSIA test your products? What challenges have you had and do you have any observations to share? Please comment and let us know.


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