What Can I Actually Make & Sell w/o Spending a Fortune on Testing?
If you've recently discovered that selling handmade products means navigating something called the Consumer Product Safety Improvement Act (CPSIA), and you immediately went looking for answers, you're not alone.
And if the answers you found left you feeling more confused or defeated than when you started, that's also completely normal.
Here's the thing about compliance information on the internet: A lot of it is general. It covers the broad rules without getting into the nuance that actually matters for small handmade businesses.
That nuance? It changes everything.
So let's talk about what you can actually make and sell, and how to think about building your product line in a smart order.
First, a quick but important note about who this applies to
This post is written for makers who are registered, or planning to register, with the CPSC as a Small Batch Manufacturer. That registration comes with real advantages, including some flexibility around third-party lab testing that larger manufacturers don't have. If you're not sure whether this applies to you, that's worth sorting out first, because it shapes everything else.
Start here: Products that need little to no testing
When I'm working with a maker who has a whole list of product ideas, I almost always start in the same place —> the products we can get moving *right now* while we figure out everything else.
For makers who sew and create fabric-based products, this is often great news. Fabric-only items, meaning products made entirely of fabric with no additional components like hardware, dyes, or trims, can often be sold with minimal or no third-party lab testing required.
Think:
- fabric-only clothing,
- fabric-only hair accessories,
- fabric-only toys, and even
- tight-fitting sleepwear made entirely of fabric.
"Fabric-only" is doing a lot of work in that sentence, so let me be clear: once you add components like a zipper, a snap, a clip, a button, or a paint that wasn't already tested, the picture changes.
But if your product is genuinely just fabric? You may have more runway than you think.
This is also where at-home testing comes in. If you're making toys intended for children 3 years and older, you can perform the Small Parts assessment yourself at home. No lab required. ASTM F963, the standard that covers most toys, can also be self-assessed at home for most handmade toys. These aren't loopholes; they're legitimate parts of the compliance framework that apply to your situation as a small batch maker.
Those tight-fitting pajamas? Same thing! Those measurements do not need to be done by a third-party lab and can be done at home. Again, not a loophole, the instructions are right in the regulation.
Next: Products where a supplier can do some of the heavy lifting
Once you've got your fabric-only products in motion, the next tier of products to tackle are those where testing is required, BUT where you can lean on your supplier's existing compliance documentation instead of paying for your own lab tests (or automatic exemptions).
I will warn: This is loads easier said than done for many components. But it is an option!
Lead content, phthalates, and flammability are all areas where a supplier's test report, Letter of Guarantee, or Certificate of Compliance can satisfy the requirement for your finished product. This means that if you're adding plastic snaps to clothing, working with clips or findings for hair accessories, or sourcing materials that need to meet certain chemical standards, the right supplier documentation can get you where you need to be without sending anything to a lab yourself.
KAM branded plastic snaps, for example, is a material that's generally well-documented for compliance purposes which is why I often suggest those specific snaps for children's clothing.
Stainless steel has been well documented and addressed by the CPSC as a material that doesn't contain Lead content in excess of 90ppm which is why it is automatically exempted from testing, so I commonly recommend it for hair accessories.
Toys intended for children over 6 years old are also worth noting here. At that age threshold, Small Parts testing is no longer required (you can do that assessment at home anyway for 3+, as mentioned above), warning labels aren't required in the same way, and heavy elements compliance can typically be sourced from your supplier. That's a meaningful difference compared to toys for younger children.
The key with this tier is learning how to ask your suppliers the right questions and knowing what documentation is actually useful. Not all supplier paperwork is created equal.
Finally: Products that do need a lab
Some products genuinely do require third-party lab testing, and it's worth being straightforward about that rather than dancing around it. Toys intended for children under 3 years old are the most common example. The testing requirements are more extensive, and supplier documentation alone won't cover everything. Products with components where good supplier compliance documentation is harder to come by also fall here.
Lab testing isn't cheap. Depending on what's being tested, individual tests can range from around $60 on the lower end to several hundred dollars or more. For some tests, like phthalates or full ASTM F963 toy testing, you're looking at the higher end of that range. This is real money, especially for a small business, and it's okay to acknowledge that.
But here's the reframe: Knowing which products require a lab, and saving those for after you've got revenue coming in from your Tier 1 and Tier 2 products, is legitimate a strategy. You don't have to figure it all out at once or test everything before you sell anything. You work through your product line in the order that makes the most sense for your business.
The bottom line
Compliance isn't all-or-nothing.
It's not "test everything before you can sell anything" or "it's too expensive so just hope for the best." There's a smart middle path, and most handmade businesses have more options than they realize, especially as registered Small Batch Manufacturers.
Start with what you can sell now. Build toward the rest. And when you get to the products that need more, you'll be in a better position, financially and knowledge-wise, to handle them.