Product guide · Crayons, paints and art supplies
What testing do crayons and kids' art supplies need?
Short answer: Every art material sold to consumers needs a toxicologist's chronic-hazard review under LHAMA (16 CFR 1500.14(b)(8)) at least every 5 years and a “Conforms to ASTM D-4236” statement. If the crayons or paints are made for kids 12 and under, they're also children's products: a CPSC-accepted lab must test them for lead (100 ppm total, 90 ppm in paint and coatings) and you must issue a CPC. LHAMA itself needs no third-party test and isn't cited on the CPC.
Last verified: October 2026. General information, not legal advice. KidsTestingLabs is an independent directory and guide: we don't test products and never issue or certify Children's Product Certificates. The US importer or US manufacturer is responsible for certifying compliance.
All art materials
What does LHAMA (ASTM D-4236) require?
Applies to art materials for any age, packaged for consumers.
- Toxicologist review: the producer (manufacturer or importer) or repackager submits each formulation to a toxicologist, a toxicologist or physician certified by a nationally recognized board, at least every 5 years and after any reformulation. A new supplier for a component counts as a reformulation.
- Report to CPSC: send the criteria the toxicologist used, plus a list of products that need chronic-hazard labeling, to CPSC's Division of Regulatory Enforcement ([email protected]).
- Conformance statement: “Conforms to ASTM Practice D-4236”, “Conforms to ASTM D-4236” or “Conforms to the health requirements of ASTM D-4236”, on the product where practicable, otherwise on the package or point-of-sale materials.
- Hazard labels: if the review finds a chronic hazard, label it under 16 CFR 1500.121 and 1500.14(b)(8).
Sources: CPSC: Art Materials guidance, CPSC: Art Materials FAQ, eCFR: 16 CFR 1500.14(b)(8) (LHAMA).
Made for kids
What extra rules apply to children's art supplies?
Children's products: designed or intended primarily for kids 12 and under.
| Requirement | Rule | Notes |
|---|---|---|
| Total lead | 100 ppm max in accessible parts | Third-party test at a CPSC-accepted lab |
| Lead in paint and surface coatings | 90 ppm max (16 CFR 1303) | Painted pencils, coated parts |
| Phthalates | 16 CFR 1307 | Only if packaged with a toy or the item meets the definition of a children's toy |
| Toy standard ASTM F963 | 16 CFR 1250 | Crayons, paints and chalks whose material isn't primarily of play value are outside the toy definition; play-value items in a kit may be toys |
| Small parts | 16 CFR 1501 | Writing materials such as crayons and chalk, modeling clay, fingerpaints, watercolors and paint sets are exempt; other kit pieces may not be |
| CPC and tracking label | 16 CFR 1110; CPSA 14(a)(5) | CPC cites the lead rules, not LHAMA |
Sources: CPSC: Art Materials FAQ, CPSC: Toy Safety Business Guidance, eCFR: 16 CFR part 1501 (small parts).
How to do it
How do I get crayons or a paint set compliant?
- Decide the audience. Packaging, themes and marketing decide whether it's a children's product.
- Book the toxicologist review for each formula; keep the report and the date (repeat within 5 years).
- Put the D-4236 conformance statement on the product or package, plus any hazard labeling the review requires.
- For children's items, test lead at a CPSC-accepted lab (check scope on the CPSC lab search), using production samples of every color.
- Issue the CPC and add tracking labels to the product and packaging.
- Retest on schedule: children's products in continuous production need periodic testing every 1, 2 or 3 years (16 CFR 1107.21).
Cost: no lab publishes art-supply prices, so request itemized quotes. CPSC's benchmark for a heavy-elements test is about $60 in China to $190 in the US (Federal Register 2020).
FAQ
Frequently asked questions
Do crayons need ASTM D4236?
Yes. Crayons are art materials, so they need a toxicologist's chronic-hazard review and the ASTM D-4236 conformance statement under LHAMA.
Do I put LHAMA or D4236 on my CPC?
No. CPSC says LHAMA isn't a testing and certification requirement, so there's no citation for it on a CPC. Cite the children's rules such as lead instead.
Does LHAMA require a CPSC-accepted lab?
No. LHAMA requires a toxicologist's review. Lead testing for children's art supplies is what needs a CPSC-accepted lab.
Can I label my crayons non-toxic?
“Non-toxic” isn't defined by regulation. CPSC staff haven't prohibited it on products that need no cautionary labeling, but using it on products that do need hazard labels could be deceptive.
How often must art materials be re-reviewed?
At least every 5 years, and whenever the formula or a component supplier changes.
Next step
Need a CPC or a lab report?
Our free CPC builder lays out all 7 required elements. No report yet? Estimate your test cost in a minute, then we'll send your product to up to 3 CPSC-accepted labs for quotes.
Sources
Official sources we checked
Checked October 2026. Rules and marketplace policies change; confirm on the source before you act.