How to read a third-party test report for a CPC

The certificate is issued by the importer or domestic manufacturer, not by the lab and not by CPSC. What makes it valid is the testing behind it: the certificate has to identify the lab whose testing it depends on, and the date and place the product was tested. A marketplace reviewer who doubts a certificate asks for the test report, because the report is the evidence and the certificate is the claim.

That is why a certificate that looks complete can still be rejected. If the report behind it names a different product, a lab CPSC has not accepted for the rule, or a test date more than a year old, the certificate has nothing to stand on.

The template above shows the blocks every third-party test report has, whatever the lab's own layout: the laboratory and its accreditation statement; the client, product and sample; the dates; a result summary listing each test conducted with its conclusion; the detailed results behind each line; and the signatures and scope notes at the end. Reports differ in typography and order, not in substance.

Read them in that order. Blocks one to three answer who tested what, and when. Block four answers which rules were tested. Blocks five and six answer whether the numbers support the summary and what the report does and does not cover.

The first block usually carries an accreditation statement: the lab is accredited to ISO/IEC 17025 by a named accreditation body. That statement is about the lab's general competence. CPSC acceptance is a separate status, granted for specific children's product safety rules, and a lab can hold the accreditation without being accepted for the rule your product is certified to.

The check is the same every time: take the lab's name from the report and match it on CPSC's laboratory search against each rule in the result summary. A lab accepted for lead in paint but not for small parts supports one line of the certificate and not the other.

A children's product must be tested periodically, and the rule sets the default interval: at least once a year. Longer intervals exist only where the manufacturer runs a production testing plan or uses an ISO/IEC 17025-accredited lab for continued compliance, and those arrangements have their own records. For a report you are handed, the practical reading is simple: a report date more than a year old is the most common reason a marketplace asks for new testing.

The report's testing dates should also match the certificate's date and place of testing. A certificate that cites a test date the report does not show is a certificate resting on a different test.

The certificate must cite each CPSC rule the product is certified to. The report's result summary lists each test conducted with a PASS or FAIL. Lay the two side by side: every rule on the certificate should appear as a tested line with a PASS. A rule on the certificate with no line in the report is unsupported, and a tested line the certificate does not cite is a rule that may apply and was left off.

For a toy, the lines you would expect to see include small parts under 16 CFR 1501 for a product intended for children under three, lead in paint under 16 CFR 1303, phthalates under 16 CFR 1307 and total lead in substrate under CPSIA section 101. Which lines belong depends on the product; the free Compliance Requirement Check tells you which rules apply before you compare.

Each detailed line gives the test method, the specimen, the measured result, the lab's reporting limit and the legal limit. ND means not detected, that is, below the reporting limit. A result under the limit is a pass for that line. One failed line fails the report for that rule, whatever an overall line says.

Some reports mark a test as outside the lab's accreditation scope, often with a symbol beside it. That does not make the result wrong, but it means the accreditation statement in block one does not cover that line, which matters if a reviewer asks how the lab is qualified for it.

It is not a certificate. The importer issues the certificate on the strength of the report, and a lab passing the product does not create a Children's Product Certificate on its own. It is not permanent; the clock above applies. It does not cover the whole production: the results relate to the samples the lab received. And it is the lab's document, so the original is kept as issued, never edited or partially reproduced without the lab's approval.

It is also not a marketplace's approval. A marketplace has its own review and may ask for the report in a particular form; the report being sound is the precondition, not the outcome.