Test guide · Chemistry
What are the lead and phthalate limits for children's products?
Short answer: Children's products (12 and under) can't have more than 100 ppm total lead in any accessible part, or more than 90 ppm lead in paint and surface coatings (16 CFR 1303). Toys and child care articles also can't contain more than 0.1% (1,000 ppm) of any of 8 listed phthalates in accessible parts (16 CFR 1307). CPSC estimates phthalate testing at about $125–$350 per component.
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.
Limits
What are the exact limits?
| Substance | Limit | Applies to | Rule |
|---|---|---|---|
| Total lead (substrate) | 100 ppm | Accessible parts of all children's products | CPSIA section 101 |
| Lead in paint and surface coatings | 90 ppm (0.009%) | Painted, coated and screen-printed parts | 16 CFR 1303 |
| Phthalates DEHP, DBP, BBP, DINP, DIBP, DPENP, DHEXP, DCHP | 0.1% (1,000 ppm) each | Children's toys; child care articles (help kids 3 and under sleep, feed, suck or teethe) | 16 CFR 1307 |
Sources: CPSC (lead limits), eCFR: 16 CFR part 1303 (lead paint), CPSC: Phthalates Business Guidance, eCFR: 16 CFR part 1307 (phthalates).
Exemptions
Which materials don't need lead or phthalate testing?
You still certify compliance on the CPC.
Lead (16 CFR 1500.91)
- Dyed or undyed textiles of natural or manufactured fibers (no non-dye treatments)
- Wood; paper and cellulosic materials; CMYK process printing inks (not spot colors or screen prints)
- Plant- and animal-derived materials such as leather, feathers, bone, shell
- Surgical and most stainless steel; precious metals such as 10k+ gold and sterling silver
Phthalates
- Certain untreated, unfinished engineered wood (16 CFR 1252.3(c)) and fibers (16 CFR 1253.2(c))
- PP, PE, general-purpose and impact polystyrene, and ABS with the additives listed in 16 CFR 1308.2(a)
Sources: eCFR: 16 CFR 1500.91 (lead determinations), CPSC: Phthalates Business Guidance, eCFR: 16 CFR part 1308 (plastics determinations).
Save money
How can I cut lead and phthalate testing costs?
Methods CPSC has accepted.
- Composite testing: one test for several colors of the same material, for lead in paint, lead content and phthalates, when conditions are met.
- XRF for lead content of certain homogeneous materials, and HDXRF (ASTM F2853-10) for lead in paint, where the lab is accepted for it.
- Component-part testing (16 CFR part 1109): rely on a supplier's certified fabric, paint or plastic test if traceability rules are followed.
- Fewer materials: each distinct material and color is another test.
Sources: CPSC: Selecting a third-party laboratory, CPSC lab scope list.
Cost
How much does lead and phthalate testing cost?
CPSC's published benchmarks.
| Test | CPSC estimate |
|---|---|
| F963 heavy elements (ICP) | ~$60 in China to ~$190 in the US per test |
| F963 heavy elements (HDXRF) | ~$40 per component |
| Phthalates | ~$125–$350 per component; can exceed $1,000 for a multi-part product |
Source: Federal Register, June 1, 2020 (CPSC test-cost benchmarks). A 2026 vendor table lists $50–$150 per component for total lead and $75–$200 per color for lead paint (EnforceIntel).
How to do it
How do I plan lead and phthalate testing?
- List every accessible component, material and color.
- Mark which ones are exempt (textiles, wood, listed plastics) and keep supplier specs.
- Send the rest to a lab accepted for the lead and phthalate methods (CPSC lab search); ask about composite testing.
- Watch results near the limit: CPSC notes measurement uncertainty, e.g. 90 ppm ± 20 ppm may not support certification against 100 ppm.
- Issue the CPC citing the lead limit, 16 CFR 1303 and 16 CFR 1307 as applicable. Related: ASTM F963, baby bottles, kids’ clothing.
FAQ
Frequently asked questions
What's the lead limit for children's products?
100 ppm total lead in any accessible component, and 90 ppm lead in paint and similar surface coatings.
Which products have phthalate limits?
Children's toys and child care articles, meaning products that help children 3 and under sleep or feed, or help them with sucking or teething.
Do textiles need lead testing?
Not if they're natural or manufactured fibers that are only dyed. Prints, coatings and non-dye treatments still need testing.
If a material is exempt from testing, do I still certify it?
Yes. CPSC says testing exemptions don't remove the underlying requirement; you still certify compliance on the CPC.
Does hard ABS plastic need phthalate testing?
Not if it's ABS with only the additives listed in 16 CFR 1308.2(a). Other plastics that are plasticized or may contain phthalates must be tested.
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.
- eCFR: 16 CFR part 1303 (lead paint)
- eCFR: 16 CFR part 1307 (phthalates)
- CPSC: Phthalates Business Guidance
- eCFR: 16 CFR 1500.91 (lead determinations)
- eCFR: 16 CFR part 1308 (plastics determinations)
- CPSC: Clothing FAQ
- Federal Register, June 1, 2020 (CPSC test-cost benchmarks)
- CPSC: Selecting a third-party laboratory
- CPSC lab search
- EnforceIntel cost table (vendor estimate, Aug 2026)