A factory test report alone is not a certificate. CPSC guidance says that children's products, meaning products designed or intended primarily for children 12 or younger, that are subject to a children's product safety rule require third-party testing and certification. The domestic manufacturer or importer must certify in a written Children's Product Certificate, based on test results from a CPSC-accepted third-party laboratory, that the product complies. As the importer of your tees, that responsibility is yours.

Which rules apply to a kids' tee

The rules that apply depend on the product and its materials. Commonly relevant ones for children's apparel include the limits on lead content in accessible components, and lead in paint or similar surface coatings, which can include some prints. The CPSC lead guidance states that accessible components of children's products must not contain more than 100 ppm total lead. Flammability rules for clothing textiles also apply to apparel. Check the CPSC list of children's product safety rules for your exact product, and ask a CPSC-accepted lab to confirm the test scope.

The seven elements

According to CPSC guidance, the certificate must identify the product, cite each applicable children's product safety rule, identify the importer or domestic manufacturer certifying it, give contact details for the person keeping test records, give the date and place of manufacture, give the date and place of testing, and identify the third-party lab. It must be in English, and no particular template is required as long as all elements are present and accurate.

eFiling from July 2026

CPSC states that from July 8, 2026, importers of most regulated consumer products must electronically file certificate data with U.S. Customs and Border Protection. Talk to your broker about how your certificate data will be submitted for each entry.

After the first order

If you materially change the product, such as a new print ink or a new trim, the changed part must be retested and a new certificate issued. Products in continuing production also need periodic testing. Pair the certificate with the permanent tracking label your kids' tees already need.

Keep the test reports behind each certificate organised by style and lot. CPSC guidance makes the certifying firm responsible for making test reports available when requested, even if a different person holds the records, so agree with your lab and factory who stores what.