Age grading
A grade is not a marketing decision. It is a statement about who will use the product, and regulators read it that way.
Below are the bands, what each one requires, and the mistake we see most often in each. Summarised for orientation — not legal advice.
Small parts, sharp points and edges, lead and phthalate content, tracking label
The strictest band. A part that fits entirely inside the small-parts cylinder fails outright — no amount of warning label makes it acceptable for this age.
Lead and phthalate content, mechanical hazards, tracking label
Small parts become permissible, but only if the grading is honest. Grading a product up to avoid a test is the single most common way importers get into trouble.
Lead content, mechanical hazards appropriate to use, tracking label
Requirements ease, but children’s product rules still apply in full. This is not an adult product simply because older children use it.
Category-specific requirements only
Only if the product is genuinely not designed or marketed for children. Packaging artwork and shelf placement are both evidence of intent — a claim of general use is not something you can assert your way into.
Requirements summarised for orientation, not as legal advice. Testing is performed by CPSC-accepted third-party laboratories and the certificate comes from them.
Three things that decide the grade
What the product is
Function and form come first. A feeding item is an under-three product regardless of what the packaging says, because that is who feeds from it.
How it is marketed
Artwork, character licensing, and the words on the box are all evidence of intended audience. A product covered in cartoon animals is difficult to argue into a general-use grade, and arguing is not a strategy you want to rely on.
Where it sits on shelf
Placement in the children’s aisle is itself evidence. If the retailer intends to merchandise it there, grade it accordingly during development rather than discovering the mismatch after the first purchase order.
The tracking label people forget
Children’s products need a permanent tracking label on the product and its packaging — manufacturer, location, date of production, and batch information. It is easy to specify and easy to forget, and it is checked.
We check for it at pre-shipment inspection on the actual goods, not only in the artwork file. Artwork having the label and product having the label are different facts.