Art and craft supplies (crayons, paint sets, markers, craft kits)
CPSC requirements for this product type. Group: Toys and play.
Certificate and rules
If it is a children's product
- Certificate
- Children's Product Certificate (CPC)
- Testing by a CPSC-accepted lab
- Required for the rules marked below
- Rules that likely apply
- 15 U.S.C. 1278a: Total lead content Third-party testing
If it is not a children's product
- Certificate
- GCC only if one of the conditional rules applies
- Testing by a CPSC-accepted lab
- Not required for children's-product reasons
- Rules that likely apply
- None for every product in this category.
Conditional rules
These rules apply only when the condition fits your product.
- If children's paint or coated items: 16 CFR part 1303
- If the item (or an attached part) is a toy, i.e. has play value for a child 12 or under: 16 CFR part 1250
- If the item (or an attached part) is a toy, or it is a child care article for ages 3 and under: 16 CFR part 1307
Notes
All art materials must meet LHAMA labeling (ASTM D4236, toxicologist review), but CPSC says LHAMA needs no certificate or third-party test. Art materials sized, decorated, or marketed for kids 12 and under (crayons, finger paints, modeling clay, craft kits) are children's products: lead testing by a CPSC-accepted lab and a CPC. Crayons, chalk, pencils, pens, modeling clay, finger paints, and paint sets are exempt from the small parts regulation (16 CFR 1501.3). Craft kits with play value can also be toys.
Other requirements
- LHAMA / FHSA labeling (16 CFR 1500.14(b)(8)); compliance required, no certificate
HTS subheadings
Subheadings commonly used for this product type (your broker confirms the full classification).
| 6-digit subheading | CPSC flags |
|---|---|
| 3213.10 | 0 flagged as certificate data required (CP2), 1 flagged as may be needed (CP1) |
| 3213.90 | 0 flagged as certificate data required (CP2), 1 flagged as may be needed (CP1) |
| 3407.00 | 0 flagged as certificate data required (CP2), 1 flagged as may be needed (CP1) |
| 9609.10 | Not on CPSC's flagged list |
Counts are the number of lines CPSC flagged under the subheading in its HTS guidance list (CP2: CPSC Certificate Related Data is Required; CP1: CPSC Certificate Related Data May be Needed). Source: CPSC HTS guidance list.
Sources
- cpsc.gov/business--manufacturing/business-education/business-guidance/art-materials
- cpsc.gov/s3fs-public/2025-12-18_eFiling-Citation-and-Testing-Exception-Codes.xlsx?VersionI
- ecfr.gov/current/title-16/part-1501/section-1501.3
- cpsc.gov/s3fs-public/CPSCGuidanceHTSListforFilingElectronicCertificates10012026.xlsx
Last verified 2026-10-18; pending review by a compliance consultant. General information, not legal advice or a determination for your product.
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