15 U.S.C. 1278a
CPSIA section 101: total lead content limit for children's products (15 U.S.C. 1278a)
Scope
Third-party testing list: CPSIA section 101: children's products (designed or intended primarily for children 12 and under) may not contain more than 100 ppm total lead in any accessible component part. Inaccessible parts (16 CFR 1500.87), exemptions (16 CFR 1500.88), and materials determined not to exceed the limit (16 CFR 1500.91, e.g., untreated textiles, wood, paper, CMYK inks, certain metals, gemstones) do not need testing. Test methods per 16 CFR 1112.15(b)(28)-(30).
CPSC footnote [2]: see CPSC's chemical test methods: https://www.cpsc.gov/Business--Manufacturing/Testing-Certification/Lab-Accreditation/Test-Methods
Certificate and testing
- The rule is not on CPSC's list of rules requiring a General Certificate of Conformity.
- Third-party testing by a CPSC-accepted lab applies for children's products, with a Children's Product Certificate.
- Lab accreditation scope paragraph: 16 CFR 1112.15(b)(28), (29), (30).
eFiling citation codes
Codes from CPSC's citation list that go on the certificate in the Registry.
| Code | Description |
|---|---|
| 1278a | 15 USC 1278a Total Lead Content for Children's Products |
Product types that use this rule
- Art and craft supplies (crayons, paint sets, markers, craft kits)
- Baby and toddler toys (under 3)
- Baby bottles, sippy cups, bibs, and feeding utensils
- Baby carriers, slings, and wraps (soft and frame)
- Baby gates and play enclosures
- Baby rattles
- Baby walkers
- Bassinets, cradles, and bedside sleepers
- Battery-powered and electronic toys (incl. kids' learning tablets)
- Bicycle helmets
- Bicycles (including kids' sidewalk bikes)
- Board games, card games, and puzzles
- Booster seats (for chairs, not car seats)
- Bunk beds and loft beds
- Button and coin cell batteries, and products that contain them
- Carpets and rugs
- Changing tables and changing pads
- Children's books (paper)
- Children's clothing (not sleepwear)
- Children's costumes and dress-up
- Children's jewelry
- Children's shoes
- Children's sleepwear (pajamas, nightgowns, robes), sizes 0-14
- Crib and play yard mattresses
- Crib sheets, baby blankets, and nursery textiles
- Cribs (full-size)
- Cribs (non-full-size, mini and portable)
- Dressers, chests, and wardrobes (clothing storage units)
- Electric bicycles (low-speed, with pedals)
- Hand-held infant carriers (carry cots and carrier seats, not car seats)
- High chairs
- Infant bath seats
- Infant bath tubs
- Infant bouncer seats
- Infant loungers, positioners, and support cushions
- Infant swings
- Kids' backpacks, lunch boxes, and school supplies
- Kids' furniture (tables, chairs, folding chairs, toy boxes, bookcases)
- Magnet sets, magnetic fidget/desk toys, and magnetic jewelry (not children's toys)
- Mattresses, futons, and mattress pads
- Nursing pillows
- Other infant sleep products (travel bassinets, in-bed sleepers, baby nests)
- Pacifiers
- Play yards (pack-and-plays)
- Plush and stuffed toys
- Pool, bath, and beach toys for children
- Portable hook-on (table) chairs
- Slime, putty, and play dough
- Stationary activity centers (activity jumpers without wheels)
- Strollers and carriages
- Teethers and teething toys
- Toddler bed rails (portable, for children)
- Toddler beds
- Toy guns, foam blasters, and look-alike firearms
- Toys for children 12 and under
- Water bead toys and kits
Sources
Last verified 2026-10-18; pending review by a compliance consultant. General information, not legal advice. Confirm with your lab and attorney.