What testing does a baby bottle need to sell in the US?

CPSC staff guidance on CPSIA section 108 says infant bottles and cups are under the jurisdiction of both CPSC and FDA: FDA covers substances that could migrate into food, and for the phthalates rule CPSC regards these articles as consumer products and “child care articles” (CPSC staff guidance, 2009). CPSC's feeding products FAQ points sellers to the Regulatory Robot for CPSC rules and to FDA for food-contact items (CPSC FAQ).

FDA's 2012 action on polycarbonate was based on industry having abandoned that use, not on a new safety finding, but the result is the same for sellers: BPA-based polycarbonate is no longer an authorized material for baby bottles.

16 CFR 1500.18 lists banned toys and children's articles: certain rattles, pacifiers that fail part 1511, articles with small parts for children under 3 (via part 1501), infant cushions and others. It doesn't name feeding bottles. The small-parts rule in part 1501 also exempts grooming, feeding and hygiene products such as dishes and eating utensils (16 CFR 1501.3(e)). Accessories sold with a bottle, like a toy attachment, can bring other rules in. Sources: eCFR: 16 CFR 1500.18, eCFR: 16 CFR part 1501 (small parts).

1. List every component: body, nipple, collar, cap, valve, printing.
2. Book a CPSC-accepted lab for phthalates (16 CFR 1307), total lead and, if decorated, lead paint. Check scope on the CPSC lab search.
3. Ask the same lab or your supplier for FDA food-contact evidence for each material that touches milk or formula.
4. Use production samples and keep material specs on file.
5. Issue a CPC citing 16 CFR part 1307, the lead content limit and 16 CFR part 1303 if applicable.
6. Mark the tracking label on the bottle (molded or printed) and the box.

Cost: no lab publishes a bottle price list, so request quotes. CPSC's benchmark for phthalate testing is about $125–$350 per component (Federal Register 2020).