Small Parts Testing for Toys, Teethers, and Pacifier Leashes (16 CFR Part 1501)

If you make a product, like toys, teethers, or pacifier leashes, for little ones under 3 years old, Small Parts testing at a CPSC-accepted lab isn’t optional and it’s the one most makers put off because they’ve heard it costs thousands.

It doesn’t have to. Testing one or two designs starts at $399, and I handle everything between you and the lab: the paperwork, the right test request, the shipping, and translating the report when it comes back.

WHAT THIS TESTING IS

Who this is for

⨀ Toys, teethers, and pacifier leashes intended for children under 3y
⨀ Other child care items for children under 3y
⨀ Small Batch Manufacturers, importers, and Amazon sellers alike

What’s tested

The lab puts each design through use-and-abuse testing (drops, pulls, and twists that mimic what a baby or toddler will actually do), then checks whether anything that comes loose fits in the small parts cylinder. That’s 16 CFR Part 1501.

This test doesn’t cover lead, phthalates, or heavy elements in your components — ask your supplier for those reports, or see Lead, Phthalates, and Heavy Elements testing. Toys also need to meet ASTM F963. Registered Small Batch Manufacturers can usually do that testing themselves; if you’d rather have the lab do it, see ASTM F963 testing.

What you’ll send

⨀ 1-3 samples of each design (no packaging needed). For sets, send the whole set.
⨀ Your completed request form

TIP: Wrap wood and other fragile pieces in bubble wrap

What you’ll get

⨀ A Small Parts test report from an ISO 17025-accredited, CPSC-accepted lab in the US
⨀ First-Party (Self) Testing Information & Record Sheet
⨀ Written Testing Plan template
⨀ Optional: A done-for-you Children’s Product Certificate for each tested design (+$75), delivered with your report

QUESTIONS ABOUT TESTING

How many designs do I have?

A new design for the Small Parts physical testing is any change in material type, construction, clip, cording, or knot. Effectively, if the difference between samples could effect the outcome, it will need to be a new sample.

For example:

1. An In-The-Hoop rabbit with long ears and safety eyes VS a giraffe with short ears, ossicones, and safety eyes are 2 different designs.
   
   
2. A plain wood stacking rainbow VS a painted wood stacking rainbow is the 'same' single design (testing one for Small Parts covers the other)
   
   
3. A teether ring with only 15mm silicone beads VS a ring with 15mm silicone beads & wood ring VS a ring with 15mm silicone beads, wood ring, & wood pendant are 3 different designs.
   
   
4. A leash with silicone beads on paracord VS satin cording are 2 different designs. A round stainless steel clip VS an obling stainless steel clip are 2 different designs. An ending 15mm silicone bead VS an ending 18mm silicone bead VS an ending 15mm wood bead are 3 different designs.

Unsure on how many designs you actually need to test? Send photos to testing@themakersresourceshop.com before you order and I'll count with you.

What tests are done?

There are a number of "use and abuse" tests that can be conducted on products and it can vary depending on the product. The most common tests are: Drop, Tension, and Torque. You can do these tests at-home to see how they will fair in the official lab testing.

1. Drop - The lab will pick up the product and drop it randomly, 10 times, from approximately 5ft onto a hard-ish flooring (think concrete with a thin rubber pad on top).
   
2. Tension - The lab will pull on any piece that can be grabbed with a thumb and forefinger. They will pull with up to 15lbs of force and hold for about 10 seconds.
   
3. Torque - The lab will repeat the tension test, adding a twist and hold for about 10 seconds.

Tips from past testing

• Wood rings: Thicker, smaller beechwood rings usually pass. The larger, thinner, yellow-ish rings often crack during the drop test (and sometimes arrive cracked!)
• Pacifier leash ending: A silicone bead at the loop end of a leash can often slide over the ending knot, particularly with satin cording that will shrink when pulled. Fusing the nylon, using a larger/wider knot, looping the cord around and back up through the last bead, or switching to a small wood bead can remedy this issue.
• Pacifier leash clips: The plastic clips with thin D-rings often fail because the clip is built to come off of the D-ring.

HOW TESTING WORKS

Process

1. Fill out the request form (link in your confirmation email). It’s private and takes about 10 minutes.
   
   
2. Ship your samples to me. Samples that arrive by Tuesday go out that Thursday. Wednesday arrivals may make it, but aren’t guaranteed.
   
   
3. I look everything over before it goes to the lab (cracks in wood, loose knots, anything likely to cause a fail) and let you know if something needs a second look.
   
   
4. The lab confirms the quote and starts testing. You’ll get a second email once testing has begun (usually within a week of shipping).
   
   
5. You get your report. Testing takes about 10-14 business days. I send your report within 1 business day of receiving it (along with your Children’s Product Certificate if you added one).
   

Plan for up to 4 weeks from the day your samples reach me to the day you have your report.

What if something fails?

It happens, and it’s exactly why testing exists. If a design fails, I’ll walk you through what failed and why, in plain language, and what to change before you pay to test again. A failed design can’t be sold as-is, but a tweak (a bigger knot, a thicker ring, a different clip) is usually all it takes. Testing fees cover the lab’s work either way, so they aren’t refundable.

IMPORTANT TO KNOW

⨀ Send samples you’re okay not getting back. The lab keeps or disposes of most samples.

⨀ Want them back? Choose return shipping ($30) on the request form. I’ll invoice for it only if the lab returns them, which isn’t guaranteed.

⨀ Testing is to US CPSC standards only, for products sold in the US.

⨀ If the lab’s quote comes in higher once they have your samples (rare, but it happens with unusual materials), I’ll check with you before anything moves forward. You’d cover the difference only if you choose to continue.

⨀ Made Legit members save 15% on every testing order. [See Made Legit here]

⨀ I’m not a lawyer, and this is a testing coordination service, not legal advice. Testing services are non-refundable.