Certification and Registration
16 CFR 1501 US. Toy Small Parts Safety Testing
Category:
CPC
Applicable Standards
16 CFR 1501 – Method for Identifying Toys and Other Articles Intended for Use by Children Under 3 Years of Age Which Present Choking, Aspiration, or Ingestion Hazards Because of Small Parts.
Purpose of the Small Parts Regulation
This regulation prevents deaths and injuries among children under three from choking, inhalation, or ingestion of small objects they may put in their mouths. It prohibits toys and other products intended for children under three from containing or releasing small parts when broken.
Which products must comply?
This regulation covers products intended for children under three, including toys, dolls, puzzles, nursery equipment, infant furniture and devices (e.g., playpens, strollers, baby bouncers, exercise equipment). A more detailed list is in 16 CFR §1501.2.
What is a widget?
A small part is any object that fits entirely within a test cylinder 2.25 inches long and 1.25 inches wide, which approximates the throat size of a child under three (see figure). See 16 CFR §1501.4. A small part may be:
1.The entire toy or object
2.A separate component of a toy or other item
3.A part that breaks off during tests simulating child use or abuse.
If a small part fits wholly in the cylinder, and the product is intended for children under three, that product is prohibited because the small part poses a choking hazard.
Widget test fixture
How to determine intent for children under three?
1.The rule lists general examples of product types intended for that age group. (16 CFR §1501.2(a))
2.It uses three factors: manufacturer’s stated intent (age labeling), advertising/promotion targeting a specific age, and whether the product is generally understood to be for children under three. (16 CFR §1501.2(b))
Are there any toys or products that are not subject to the Small Parts Regulation?
1.Yes – balloons, books and other paper products, phonograph records, writing materials (crayons, chalk, pencils, pens), modeling clays, finger paints, watercolors and paint kits are exempt because they may break into small parts under use‑and‑abuse testing. Children’s clothing and accessories (shoelace holders, buttons), toiletry, feeding, and hygiene items (diaper pins, hair clips, toothbrushes, cups, plates, utensils) are also exempt because they must be small to function. (See 16 CFR §1501.3 & 4(b).)
2.Rattles and pacifiers have their own small‑part requirements. (16 CFR §§1510.3 and 1511.5(d).)
3.Products for children under three must comply with the small‑parts rule unless specifically exempted.
What testing requirements apply?
These products must not release pieces that fit entirely in the small‑parts cylinder after impact, bending, torsion, tensile, and compression tests. These simulate forces during normal use and misuse. If pieces fit the cylinder, they pose a choking hazard.
Test procedures and force levels: for ages 0–18 months – 16 CFR §1500.51; for 18–36 months – 16 CFR §1500.52.
Other warning requirements
Toys and games that are small parts or contain them, intended for ages 3 to 6, must bear a label warning buyers not to give them to children under 3 due to choking hazard. Marbles, small balls, and balloons also require similar warnings (16 CFR §1500.19).
Other CPSC requirements for all products for children under three
1. Toys and children’s products must not have hazardous sharp points (16 C.F.R. 1500.48).
2. or edges (16 C.F.R. 1500.49),
3. Paint or any other similar surface coating containing more than 0.009% lead is prohibited (16 C.F.R. Part 1303).
4. May not contain other hazardous chemicals (16 C.F.R. 1500.3(a)(15)).
5. or exceed the flammable limits (16 C.F.R. 1500.44).
Additional requirements for specific products
● Pacifiers - 16 C.F.R. 1511
●Rattles – 16 C.F.R. 1510
●Crib – 16 C.F.R. 1508, 1509
●Baby pillows and cushions—Title 16, Code of Federal Regulations, Section 1500.18(a)(16)
● Baby walkers, trampolines, and jumping mats – 15 CFR § 1500.18(a)(6)
● Electric toys – 16 CFR Part 1505
● Dolls, stuffed toys, and other products that may cause tearing or puncture injuries. - C.F.R. 16 Part 1500, Subpart A, Sections 1500.18(a)(1), (2), and (3)
●Small ball - 16 C.F.R. 1500.18(a)(17)
Other applicable standards
ASTM International coordinates voluntary industry standards that complement mandatory ones. For the Consumer Safety Specification for Toy Safety (ASTM F‑963) and other voluntary standards for children’s products, please contact customer service.
The U.S. market has strong demand for infant and child products, yet regulatory oversight is stringent. SATISFY can provide compliance guidance for infant and child products – please contact SATISFY customer service for more details.
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