The CPSC lead limit for children’s products is 100 parts per million (ppm) of total lead content in every accessible part of a product designed or intended primarily for children 12 and younger. Paint and similar surface coatings on children’s products face a separate, tighter limit of 0.009 percent, or 90 ppm. Both apply to children’s products made in or imported into the United States, both require testing at a CPSC-accepted laboratory, and a Children’s Product Certificate (CPC) is required even when every part is inaccessible or made of a material CPSC has determined does not exceed the limit (CPSC, data checked 2026-10-13).
This guide sets out CPSC’s criteria for kids’ jewelry, toys, backpacks and printed clothing so you can run the check yourself; it does not decide whether any specific product complies.
Sources: CPSC Total Lead Content FAQ, CPSC Small Batch Manufacturers and Third Party Testing, 15 U.S.C. 1278a via govinfo, and 16 CFR 1500.87, 1500.88, 1500.91, 16 CFR 1303.1 and 16 CFR part 1252 via eCFR (up to date as of 2026-10-08). Data checked 2026-10-13.
Two Limits, Not One: 100 ppm Lead Content vs. 90 ppm Lead Paint
| Total lead content | Lead in paint and surface coatings | |
|---|---|---|
| Limit | 100 ppm by weight, any accessible part | 0.009% (90 ppm) of the dried paint film or nonvolatile content |
| Legal basis | CPSIA section 101(a), 15 U.S.C. 1278a | 16 CFR 1303.1, as lowered by CPSIA section 101(f) |
| What it covers | Substrates: metal, plastic, vinyl, glass, fabric and so on | Paint and similar surface coatings |
| In force since | August 14, 2011 (three years after August 14, 2008) | August 14, 2009 |
| Test methods CPSC names | CPSC-CH-E1001-08.3 (metal), CPSC-CH-E1002-08.3 (non-metal) | Separate paint methods; CPSC’s FAQ names ASTM F2853 (XRF) as approved for lead in paint |
The statute is blunt about consequences: a children’s product that contains more lead than the limit “shall be treated as a banned hazardous substance under the Federal Hazardous Substances Act.” Part 1303 likewise declares “toys and other articles intended for use by children” that bear lead-containing paint to be banned hazardous products. Penalty amounts are not stated on CPSC’s lead FAQ, and this guide does not quote them.
A painted metal zipper pull is therefore two checks: paint against 90 ppm, metal against 100 ppm.
Which Products Are in Scope
The 100 ppm limit applies to “children’s products,” the CPSA term for consumer products designed or intended primarily for children 12 and younger. CPSC’s four factors for that call, including how your listing presents the product, are covered in our Children’s Product Certificate guide.
CPSC’s FAQ adds these scope answers:
- Art materials. Children’s art materials designed or intended primarily for children 12 and younger are subject to the lead limits, on top of LHAMA labeling.
- Packaging. Disposable packaging is not subject to the third-party testing and certification requirements. Packaging meant to be reused with the product, such as a heavy gauge reusable bag to hold blocks, is treated as part of the product.
- Books. Ordinary books and paper-based printed materials are excluded from third-party lead testing, but not books with inherent play value. Ordinary printing on paper must still meet 100 ppm.
- Used products. Certain used children’s products are excluded from the total lead content requirements, but “this exclusion does NOT apply to children’s metal jewelry.”
State law runs alongside. CPSC’s FAQ notes that “certain states, like Illinois and California, have other regulatory requirements concerning lead content.” California’s Proposition 65 is a different regime, covered in our Prop 65 guide.
What Counts as Accessible
The limit applies only to parts a child can reach. Under 16 CFR 1500.87(b), a part is not accessible if it “is not physically exposed by reason of a sealed covering or casing and does not become physically exposed through reasonably foreseeable use and abuse of the product including swallowing, mouthing, breaking, or other children’s activities, and the aging of the product.”
Four details decide most real cases:
- Coatings are not a barrier. “Paint, coatings, or electroplating may not be considered to be a barrier that would render lead in the substrate to be inaccessible to a child.” Gold-tone plating on a base-metal charm does not hide the base metal.
- The probe decides. Accessibility is assessed with the sharp point and edge probes of 16 CFR 1500.48 and 1500.49: a part is accessible if any portion of the specified probe segment can contact it.
- Use-and-abuse testing comes first. For each age band (18 months or less, over 18 to 36 months, over 36 to 96 months, and over 96 months through 12 years) section 1500.87 names which tests of 16 CFR 1500.50 to 1500.53 apply, excluding the bite tests.
- Fabric only counts at 5 cm. A lead-containing part enclosed by fabric that passes the use-and-abuse tests is inaccessible “unless the product or part of the product in one dimension is smaller than 5 centimeters.”
Printed Clothing and Screen Prints
CPSC’s FAQ splits textile inks three ways:
| How the ink behaves | How CPSC staff treats it | Limit that applies |
|---|---|---|
| Fuses with the fabric and cannot be scraped off | Part of the substrate | 100 ppm total lead content |
| Scrapes off the fabric | A surface coating | 90 ppm lead paint limit |
| Absorbs into the fibers like a dye | A dyed textile | Can fall under the textile determination |
In the FAQ’s words, “where the ink cannot be scraped off the textile, CPSC staff treats the ink as being part of the substrate,” and “if the ink, paint, or pigment scrapes off then it is considered to be a surface coating.”
The textile determination in 16 CFR 1500.91(d)(7) covers dyed or undyed natural and manufactured fibers, but excludes textiles with “treatments or applications that do not consist entirely of dyes.” The CMYK ink determination in (d)(6) expressly excludes “screen prints, transfers, decals, or other prints.” A screen-printed graphic or heat transfer therefore needs its own lead result.
Materials CPSC Says Do Not Exceed the Limit
Section 1500.91 lists materials the Commission has determined do not exceed the lead limits, provided they have not “been treated or adulterated with the addition of materials that could result in the addition of lead”:
| Group | Listed materials |
|---|---|
| Gemstones | Diamond, ruby, sapphire, emerald; semiprecious stones not associated with lead minerals |
| Natural | Pearls; wood; plant- and animal-derived materials such as shells, bone, feathers, leather |
| Paper | Paper and cellulosic materials, plus coatings that become part of the substrate |
| Inks | CMYK process printing inks, excluding spot colors and after-treatment prints |
| Textiles | Dyed or undyed natural and manufactured fibers, with no non-dye treatments |
| Metals | Stainless and surgical steel within UNS S13800-S66286 except 303Pb; gold of at least 10 karat; sterling silver; platinum-group metals; titanium |
The metals entry applies only where no lead is intentionally added and “does not include the non-steel or non-precious metal components of a product, such as solder or base metals in electroplate, clad, or fill applications.” Gold-filled or plated jewelry is not covered by it.
CPSC’s FAQ also mentions certain untreated and unfinished engineered wood products under 16 CFR part 1252.
The determinations relieve you of testing, not of the limit. CPSC’s FAQ: “This does NOT provide an exemption from meeting the total lead content requirement,” and “firms are still expected to certify compliance with the total lead content requirement in a CPC.”
Special Cases: Electronics, Bicycles, Off-Highway Vehicles
- Children’s electronics. Under 16 CFR 1500.88, where lead is needed for a component to work and meeting the limit is not technologically feasible, specific exemptions apply: for example lead in steel below 0.35% (3,500 ppm), in aluminum below 0.4% (4,000 ppm), in copper-based alloys below 4% (40,000 ppm), plus lead in glass of electronic components and in compliant pin connectors. Removable parts such as battery packs and light bulbs that are inaccessible when assembled are not subject to the limits.
- Bicycles. CPSC’s FAQ says “metal components of bicycles and related products are permitted to contain up to 300 ppm of lead,” and children’s bicycles must still be third-party tested and certified.
- Off-highway vehicles. CPSC’s FAQ excludes off-highway vehicles, including snowmobiles, from the total lead limits.
Testing and the Certificate
Manufacturers and importers of children’s products “must third-party test their product using a CPSC-accepted laboratory,” and must then certify, based on those results, in a CPC.
From the same FAQ:
- Component testing. You may rely on a component supplier’s testing or certificate “provided that certain conditions are satisfied,” including due care to verify it and access to the underlying records.
- XRF. “Some XRF technology is approved to test certain types of homogenous materials, with limitations.”
- EU soluble lead results do not substitute. CPSC says “other countries have requirements and testing methods that differ from those of the CPSC,” so total lead must still be tested.
Registered small batch manufacturers get some relief. CPSC lists “Total lead content” under Group B, where alternatives to third-party testing can be used, but lists “Lead in paint and similar surface coating” under Group A, where small batch manufacturers “do not receive any testing burden relief.” Registration is required, and CPSC adds that the relief “is not an exemption to any applicable requirements.”
What goes on the CPC is covered in our CPC guide; importers should also read our CPSC eFiling guide.
What This Means for Kids’ Jewelry, Toys, Backpacks and Printed Clothing
- Kids’ jewelry. Base-metal charms, chains and clasps carry the most risk, plating does not shield them, and used metal jewelry gets no exclusion. Sterling or 10-karat-plus gold parts fall under the metals determination; solder and plated base metal do not.
- Toys. Painted surfaces go against 90 ppm; plastic, metal and vinyl substrates against 100 ppm. Small-parts labeling is in our choking hazard warning guide.
- Backpacks. Plain dyed fabric can rely on the textile determination; zipper pulls, buckles, vinyl patches and prints need results.
- Printed clothing. Classify each print with the scrape logic above; snaps and metal trims are separate components.
How Amazon collects certificates and test reports is covered in our Manage Your Compliance guide. If you learn a product exceeds a limit, read our CPSC Section 15(b) guide and Amazon product recalls guide.
Common Mistakes
- Quoting one number for everything. Paint is 90 ppm; substrates are 100 ppm.
- Treating plating as a seal. Paint, coatings and electroplating are not barriers.
- Skipping the CPC because a material is on the determination list. The FAQ says a CPC is still required.
- Sending an EU soluble-lead report. CPSC requires total lead testing by its methods.
- Assuming a screen print is covered by the textile determination. Only dye-like inks are.
- Expecting small batch status to cover paint. Lead in paint stays in Group A.
Pre-Listing Checklist
- List every component and mark each accessible or inaccessible under 16 CFR 1500.87.
- Separate paint and surface coatings (90 ppm) from substrates (100 ppm).
- Mark components covered by 16 CFR 1500.91 or part 1252, and check the untreated and unadulterated condition.
- Classify each textile print as substrate, coating or dye-like.
- Test the rest at a CPSC-accepted lab with CPSC’s named methods.
- Issue a CPC covering both limits, even for exempt or inaccessible parts.
- Check state requirements, including Illinois and California.
Frequently Asked Questions
What is the CPSC lead limit for children’s products?
100 ppm of total lead content in any accessible part of a children’s product, in force since August 14, 2011 under 15 U.S.C. 1278a. Paint and surface coatings have a separate 90 ppm limit under 16 CFR 1303 (data checked 2026-10-13).
Does children’s jewelry have to meet the 100 ppm lead limit?
Yes, if the jewelry is designed or intended primarily for children 12 and younger, because that makes it a children’s product. Adult jewelry is not. Electroplating does not make base metal inaccessible, and the used-product exclusion does not apply to children’s metal jewelry.
Are screen prints on kids’ clothing tested for lead?
CPSC staff treat ink that cannot be scraped off as substrate (100 ppm) and ink that scrapes off as a surface coating (90 ppm). Screen prints and transfers are excluded from the CMYK ink determination.
If my product is made only of exempt materials, do I still need a CPC?
Yes. CPSC’s FAQ says a CPC is required even when all component parts are inaccessible or covered by the Commission’s lead determinations.
Conclusion
Separate paint (90 ppm) from substrates (100 ppm), drop inaccessible parts using CPSC’s probe and use-and-abuse tests, set aside materials on the 1500.91 list, test what remains at a CPSC-accepted lab, and certify all of it in a CPC.