Rewritten 10 August 2026 — this guide has been rebuilt on the statutes, the Code of Federal Regulations, EU directives and the tariff schedule. Its compliance section named the wrong European standard, misstated the age the US rules reach, and applied a rule to backpacks that does not cover them. All corrected below.
A note on who wrote this. Backper sells children's backpacks and this page previously ended by claiming we "work to full CPSIA, EN 71, and REACH compliance." Two of those three were the wrong thing to claim. EN 71 is a toy standard that does not apply to an ordinary school backpack, and compliance with it is never mandatory even for toys. And the certificate the page implied we could supply is one that, by law, we cannot issue for you — it belongs to the importer.
That last point is the most useful thing on this page and it costs us a sales line. A supplier offering to "provide your CPC" is offering something that is not theirs to give.
Children's products are the one bag category where the compliance section of a supplier's page ought to be the most reliable part. In practice it is the least. Going back through this page against the actual statutes, five of its claims were wrong, one was dangerously incomplete, and the single biggest obligation on an EU-facing buyer was missing entirely.
What follows is the corrected version, with the citation for each point. Three things in it will save a buyer money or trouble: who actually owes the certificate, which rules do not apply (a longer list than the ones that do), and the one spec decision that moves duty by eleven points.
The age boundaries, which are not one boundary
The old version said CPSIA is required "for children under 12". The statute says something different, and the difference includes an entire year group.
15 U.S.C. 2052(a)(2) defines a children's product as "a consumer product designed or intended primarily for children 12 years of age or younger." A bag marketed to twelve-year-olds is in scope. "Under 12" is not the test and never was.
| Rule | Reaches | What it does |
|---|---|---|
| 16 CFR 1501 small parts | Under 3 | Bans a toy or other article for under-3s that fits entirely within a test cylinder, after use-and-abuse testing |
| 16 CFR 1307, child care article | 3 and younger | Phthalate limits — but only for articles that facilitate sleep, feeding, sucking or teething |
| 16 CFR 1130 registration cards | Under 5 | Durable infant or toddler products on an enumerated list. Schoolbags are not on it |
| CPSIA children's product | 12 or younger | Third-party testing, Children's Product Certificate, permanent tracking labels, 100 ppm lead |
| 16 CFR 1307, children's toy | 12 or younger | Phthalate limits — only where the product is used by the child when the child plays |
| ASTM F963 via 16 CFR 1250 | Under 14 | Mandatory toy safety standard. Applies to playthings, not to carrying articles |
| EU and UK toy definition | Under 14 | Directive 2009/48/EC Art. 2(1); Toys (Safety) Regulations 2011 reg. 4(2) |
Note the mismatch that catches people: ASTM F963 reaches under-14s, but the certificate and third-party testing obligations reach only 12-and-under. A toy marketed at thirteen-year-olds must meet the standard without triggering a CPC.
And a second correction, which is commercially larger. The old page implied CPSIA attaches automatically to "any kids backpack". It does not. 16 CFR 1200.2(b)(1): "A general use product means a consumer product that is not designed or intended primarily for use by children 12 years old or younger." Whether your bag is a children's product turns on a four-factor test. Two of the factors are yours to control — your own labelling, and your packaging and advertising. The other two are not: what consumers commonly recognise the product as, and CPSC's Age Determination Guidelines. So the same physical bag can land differently in two catalogues, but you cannot elect out of children's-product status by catalogue placement alone, and a buyer who tries will be quoted factors three and four.
Lead and phthalates are not the same rule, and one of them does not apply
The old version said CPSIA "regulates lead and phthalate content in children's products". The lead half is right. The phthalate half is wrong.
16 CFR 1307.1 prohibits the manufacture, sale or import of "any children's toy or child care article" containing the phthalates specified at 1307.3, where the limit is 0.1% — not in children's products generally. The definitions at 1307.2 are narrow: a children's toy is a product "for use by the child when the child plays"; a child care article is one designed "to facilitate sleep or the feeding of children age 3 and younger, or to help such children with sucking or teething."
A school or daycare backpack is neither. It is outside 16 CFR 1307. Anyone telling you a kids backpack automatically needs phthalate testing is over-reaching — though a retailer may impose it contractually, and a plush-fronted toddler bag could genuinely cross into toy territory.
Lead: two limits, on different parts of the bag
| Limit | Instrument | What it reaches on a backpack |
|---|---|---|
| 100 ppm total lead | 15 U.S.C. 1278a | The substrate — fabric, zip sliders, rivets, D-rings, hardware |
| 90 ppm lead in paint | 16 CFR 1303 | Any coating forming a solid film on the surface: painted hardware, PU or PVC coatings, screen-print and heat-transfer films sitting on the fabric |
16 CFR 1303.2(b)(1) excludes from the paint rule any material that becomes part of the substrate — so a dye or an ink that penetrates the fibre is outside 1303, while the fabric it is on still owes 100 ppm. And 16 CFR 1500.87 is not the limit, as the previous version implied; it is the inaccessible-parts carve-out, and it states expressly that "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." A coated zinc zipper pull cannot be argued inaccessible.
The textile exemption everyone quotes is real and is quoted wrong. 16 CFR 1500.91(d)(7) determines that textiles do not require third-party lead testing — but read the parenthetical: it covers textiles "excluding any textiles that contain treatments or applications that do not consist entirely of dyes."
A coated 600D polyester, a PU-backed panel, a screen-printed or heat-transferred graphic — all of those carry a treatment that is not a dye, and all of them fall outside the determination. Most backpack fabric is coated. The bare dyed-only fabric is the exception in this category, not the rule. And 1500.91(c) provides that a determination "does not relieve the material or product from complying with the applicable lead limit… if the product or material is changed or altered so that it exceeds the lead content limits" — the determination removes the third-party testing obligation, not the underlying duty to comply.
What has actually failed, in the recall record
We went through CPSC's recall database rather than reasoning from first principles. The pattern is unambiguous.
| Recall | Date | Product | What failed |
|---|---|---|---|
| 22-731 | 24 Feb 2022 | Children's leather handbags, ~1,050 units | The metal zipper slider, zipper O-ring, D-ring, rivet and stud exceeded the lead content ban |
| 12-064 | 22 Dec 2011 | Children's travel cases, ~139,000 units | The surface coating exceeded the lead paint standard |
| 08039 | 23 Oct 2007 | Game pieces sold with character backpacks | Detached magnets — the accessory failed, not the bag |
| 98151 | 18 Aug 1998 | Character backpacks and rolling luggage | Lead paint in the printed artwork |
| 93060 | 2 Apr 1993 | Children's carry-all bags and backpacks | Surface coating on the zipper pull, and inks, exceeded lead limits |
Not one of these was the textile shell. Every lead event hit metal trim or a printed or painted coating — which is exactly the set of components that 1500.91(d)(7) does not exempt. Put your QC budget on hardware and print, and name 15 U.S.C. 1278a and 16 CFR 1303 against those components specifically on the certificate. Note also how thin the record is: the most recent entry above is a children's handbag in 2022, and we found no children's schoolbag recall in the database in the last fifteen years. If anyone implies a constant recall drumbeat in this category, it is not in the data.
The certificate is yours, not your supplier's
This is the correction that costs us a sales line, so it goes in plainly.
16 CFR 1110.7: for imported products, "the importer, as defined in this part, is the finished product certifier that must issue a finished product certificate." Not the factory. Not the trading company. The US importer of record.
A supplier can — and should — give you the accredited third-party test reports that the certificate rests on. It cannot issue the certificate, and a document headed "CPC" on a factory letterhead does not discharge your obligation. The liability is the importer's.
| Element |
|---|
| Product identification, including a unique identifier such as a model number, GTIN or UPC |
| Each rule, ban, standard or regulation the product is certified to |
| Identification and contact details of the certifier |
| Name and contact for the individual maintaining the test records |
| Date and place of manufacture |
| Date and place of testing |
| The certifier's attestation, in the wording the rule prescribes — for eFiled certificates it is made in CPSC's Product Registry rather than signed |
And the change that has already happened: under the final rule at 90 FR 1800, published 8 January 2025, importers must eFile the certificate data into CBP's ACE at the time of entry. That has applied since 8 July 2026; foreign-trade-zone entries follow on 8 January 2027. Domestic manufacturers do not eFile. Anything you read written in the future tense about eFiling is stale.
Tracking labels: the old list was missing a third of it
The previous version said the label must identify "the manufacturer, production date, and batch number". 15 U.S.C. 2063(a)(5) requires marks that let the ultimate purchaser ascertain the manufacturer or private labeler, the location and date of production, and cohort information such as batch or run number — and it requires the marks on the product and its packaging, to the extent practicable.
Three things were missing: location of production, the private labeler alternative — which is the relevant one for any buyer putting their own brand on a factory bag — and the packaging requirement. On permanency, CPSC's test is a mark "that can reasonably be expected to remain on the product during the useful life of the product", which in practice means a sewn-in woven label rather than a hangtag or a printed sticker.
EN 71 is the wrong standard, twice over
The old version said EN 71 is "required for kids products in the EU". That sentence is wrong in two independent ways, and it is the single most repeated error in this category.
First: an ordinary children's backpack is not a toy in EU law. Directive 2009/48/EC applies to products "designed or intended, whether or not exclusively, for use in play by children under 14". Its Annex I, item 19, lists among products expressly not considered toys: "Fashion accessories for children which are not for use in play." A carrying article with a utility function and no designed-in play value falls there. EN 71 does not apply to it at all.
Second: EN 71 is never "required", even for real toys. It is a harmonised standard. Article 13 gives it its only legal effect: toys conforming to harmonised standards "shall be presumed to be in conformity with the requirements covered by those standards". The binding obligations are the essential safety requirements in Article 10 and Annex II. EN 71 is one route to demonstrating them, not the law itself.
So a supplier waving an "EN 71 certificate" for a plain backpack is usually telling you only that somebody ran an EN 71-3 heavy-metals migration test. That is a perfectly good test. It is not a legal requirement for this product, and it is not evidence of anything the law asks for.
The edge case is real and worth knowing. The Commission's own explanatory guidance names backpacks directly when discussing dual-function products, and EU Guidance Document No. 11 treats soft filled animal-shaped purses and backpacks as toys, classified as soft toys in the under-36-months group — noting specifically the choking risk from cords and straps. So: a plush or character-shaped bag with cuddle value is a toy and takes the full regime including CE marking. A plain rucksack in a cartoon print is not.
Do not CE-mark a backpack. The Commission states that CE marking is compulsory only for products covered by the relevant directives, and that "it is forbidden to affix CE marking to other products." A plain children's backpack is not a toy and is not PPE. Chinese suppliers routinely offer "CE certificates" for bags; a buyer who prints CE on such a product is manufacturing a violation, not a compliance asset. The exception matters here, though: add LED lights, a USB pass-through or an integrated power bank and the bag comes within the EMC Directive, RoHS and the battery rules — at which point CE marking is required. Lit children's bags are common, so establish which product you are actually making before deciding either way.
What actually applies in the EU, and it is a market-access condition
The obligation the old version omitted entirely is the one that decides whether you can sell at all.
Article 16(1) of the General Product Safety Regulation (EU) 2023/988, applicable since 13 December 2024: "A product covered by this Regulation shall not be placed on the market unless there is an economic operator established in the Union who is responsible for the tasks set out in Article 4(3) of Regulation (EU) 2019/1020 in respect to that product." Article 16(3) requires that operator's name and contact details to appear on the product, its packaging, the parcel or an accompanying document.
No responsible person, no lawful placing on the EU market. It applies to the backpack whether or not anyone mentions EN 71. The cascade runs: EU-established manufacturer, then importer, then an authorised representative under written mandate, then a fulfilment service provider.
| Entry | Substance | Limit | Why it reaches a backpack |
|---|---|---|---|
| 43 | Azo dyes releasing listed aromatic amines | >30 ppm in the finished article | Scope names handbags, purses, wallets and briefcases — textile and leather articles in direct and prolonged skin contact |
| 50 | Eight PAHs | >1 mg/kg per PAH in rubber or plastic components | Plasticised strap padding, PVC trims, rubber grips — components in direct, prolonged or repeated skin contact |
| 51 | DEHP, DBP, BBP, DIBP | 0.1% of the plasticised material | Extended beyond toys since 7 July 2020 to articles with plasticised material contacting mucous membranes or in prolonged contact with skin |
| 23 | Cadmium | 0.01% of the plastic material | Coloured plastic parts and components |
| 27 | Nickel | >0.5 µg/cm²/week release | Only where zips, rivets or buckles are in prolonged direct skin contact — arguable for a strap buckle, weak for a front zip |
| 52 | DINP, DIDP, DNOP | 0.1% by mass | Toys and childcare articles that can be placed in the mouth by children — a plain backpack is out of scope |
Entries 43, 50 and 51 are the three worth naming in a specification. Entry 63 (lead) is narrower than it looks: it reaches articles that may be placed in the mouth by children, which could catch a small zip charm but not the bag body.
The UK now differs, and Northern Ireland differs again. The Toys (Safety) Regulations 2011 carry the identical exclusion at Schedule 1 paragraph 20, so a plain backpack is not a toy in Great Britain either and UKCA marking does not apply. But Great Britain still runs the General Product Safety Regulations 2005 and has not adopted the EU's 2023 GPSR — so there is no responsible-person-in-territory requirement for GB. Northern Ireland does apply EU 2023/988 under the Windsor Framework, including Article 16. A seller shipping into Northern Ireland needs an EU- or NI-established responsible person; one shipping only within Great Britain does not.
The visibility standard that actually exists
The old version listed "high-visibility reflective accents" as a nice-to-have beyond compliance. In the German-speaking markets it is closer to a condition of sale, and there is a real standard behind it with real numbers.
DIN 58124:2018-10, Schulranzen, sets two minima: at least 20% fluorescent material and at least 10% retroreflective material. Published summaries of the standard disagree on exactly which surfaces each minimum is measured against — some say the visible surface, others the front and side or the rear and side panels — so specify the measurement basis with your supplier rather than assuming it. Published summaries of the standard describe orange-red and yellow as the prescribed fluorescent colours; we could not confirm from a primary source whether the 2018 revision widened that list, so we have not printed one.
It is a voluntary standard, not a statute — but if a manufacturer advertises conformity and the product does not meet it, market surveillance can act on the misleading claim. In German retail and school procurement the marking "entspricht DIN 58124" is what buyers look for. If you are selling into Germany, Austria or Switzerland, this is the specification to build to, and it is a design constraint rather than a trim detail. Do not add the two figures together: a single tape can be both fluorescent and retroreflective, so they are not necessarily disjoint shares of the bag.
Two traps here. First, the 1.2 kg empty-weight figure should not be attributed to DIN 58124. We could find no weight cap in the published summaries of the standard. The 1.2 kg maximum, the 10%-of-body-weight loaded guidance and the 40 mm minimum strap width circulate as German school-safety recommendations — though one German source states the body-weight figure sat inside DIN 58124 until the 2010 revision removed it, so treat the provenance as unsettled rather than clean.
Second, do not let a bag be marketed to EN 17353. That standard covers enhanced-visibility garments and body-worn devices, and products compliant with it are Category II PPE under Regulation (EU) 2016/425 — requiring notified-body type examination and CE marking. Claiming it would drag an otherwise unregulated backpack into the PPE regime. If a supplier offers EN 17353 for a bag, either they mean a detachable hanging reflector, or the claim is unsupportable.
Four rules that get quoted here and do not apply
| Rule | What it actually covers | Why a backpack is out |
|---|---|---|
| 16 CFR 1120 drawstrings | Children's upper outerwear in sizes 2T to 16 with drawstrings, non-conforming to ASTM F1816-97 | Upper outerwear means garments worn over other garments. A backpack is not a garment — and neither is a drawstring cinch bag, whose cord is a closure, not a neck or hood cord |
| 16 CFR 1610 flammability | Textiles and textile products for clothing use | A backpack is not wearing apparel. An article saying "our fabric passes 1610 because it's polyester" is right by accident and wrong in reasoning — you never reach the exemptions because you were never in scope |
| 16 CFR 1130 registration cards | An enumerated list of durable infant or toddler products | Schoolbags are not on the list. But frame-type infant carriers are — see the warning below |
| 16 CFR 1307 phthalates | Children's toys and child care articles | A school or daycare backpack is neither |
The one place the word "backpack" hides a regulatory cliff. 16 CFR 1130.2 lists "Infant carrier, including soft infant and toddler carriers, hand-held infant carriers, sling carriers, and frame child carriers." A frame backpack child carrier — the hiking carrier you wear a baby in — is a durable infant or toddler product. It owes registration cards under 1130 and is subject to ASTM F2549-22 via 16 CFR 1230 — not 16 CFR 1226, which is the separate rule for soft infant and toddler carriers. It is a completely different regulatory product from a school backpack that happens to share a word. Keep the two apart in your catalogue, your specifications and your conversations with suppliers.
The spec decision that moves duty eleven points
A children's school bag may not classify as a backpack at all — heading 4202.12 covers "school satchels" by name. Buyers worry about this. They should worry about something else.
| Outer surface | School satchel, 4202.12 | Backpack, 4202.92 | Difference |
|---|---|---|---|
| Other vegetable fibres | 4202.12.60 — 5.7% | 4202.92.20 — 5.7% | None |
| Cotton | 4202.12.40 — 6.3% | 4202.92.15 — 6.3% | None |
| Man-made fibres | 4202.12.81 — 17.6% | 4202.92.3120 — 17.6% | None |
| Plastic sheeting | 4202.12.29 — 20% | 4202.92.45 — 20% | None |
Confirmed inside a single CBP ruling: NY N303113, 22 March 2019, classified a polyester backpack at 4202.92.3120 and a polyester suitcase at 4202.12.8170, both at 17.6%, with the same Chapter 99 duty added to each.
So the classification is a wash and the fibre is everything. Cotton at 6.3% against man-made fibre at 17.6% is an 11.3 percentage point swing on the same bag — confirmed in NY N331692, which classified a cotton drawstring backpack from India at 4202.92.1500, 6.3%. For a daycare or camp programme where the bag is small and the aesthetic is soft anyway, "should this be cotton canvas?" is a far more consequential question than any of the ones this page used to lead with.
For completeness, the classification test itself: two straps worn on the back makes it a backpack under 4202.92, however soft, small or novelty-shaped. In HQ H307211 a completely unstructured child's drawstring bag with no frame was still classified as a backpack, because it had a functional storage area and straps that let it be carried as one — so softness did not take it out of 4202.92. The ruling decides that case rather than announcing a rule, but it is the closest authority we found on the point. The school-satchel rulings we found — NY G87110 and NY E84353 among them — turn on the article being a case for carrying school books, typically single-strap with a flap, rather than on any strap-count rule that CBP has stated. The most recent ruling we found, NY N360038 of 14 April 2026, classified a child's polyester backpack at 4202.92.3120, 17.6%, on the strength of two back-worn straps.
A trap in the tariff schedule itself. Several backpack-specific duty provisions are still printed in Chapter 99 and will show as Free — or, at 9902.12.39, as a reduced 4% — in a naive lookup. They run from 9902.12.37 to .45 and cover doll-carrying backpacks, backpacks with moulded plastic shells, and a nylon construction valued at $14 or more but not over $21 each. All of them expired on 31 December 2020, along with GSP. None is claimable. And there is no US duty relief for children's bags as such, none for backpacks donated to schools or non-profits, and nothing in Chapter 98 subchapter X that reaches them. In the EU, relief for goods imported by approved charitable organisations for free distribution does exist under Regulation (EC) 1186/2009 Articles 61 to 65 — but it turns on the importer's status, not on the product being for children.
The prices we published
We previously quoted $10 to $18 a unit at 100 to 250 pieces, $14 to $24 at 500 to 1,000, $18 to $32 at 1,500 or more, and $2 to $5 for name embroidery. We searched for something to check them against and found nothing.
That search was not cursory. It covered CBP rulings, USAspending and SAM.gov federal awards, GSA published schedule price lists, district and state bid tabulations across a dozen states, five cooperative purchasing vehicles, four bid aggregators, and the procurement pages of the large youth non-profits. No published document gives a per-unit price for a decorated children's backpack at any quantity. Public-sector buyers publish plenty of prices in this world; they do not publish this one.
Two honest observations to put in place of the numbers. First, the deleted ladder rose with volume — $10-18 at 100-250, then $14-24 at 500-1,000 — which inverts how quantity breaks work and is the clearest sign nobody had checked it. Second, the only genuinely public value data is US Census and USITC average unit value by tariff line for 4202.92.3120, which anyone can pull. It does not separate children's bags from adult ones, and it is customs value rather than landed cost, so it is a floor on your knowledge rather than an answer. It is still more than any supplier's price range is.
Sourcing a children's programme with Backper
Applying this page's own tests to us:
| Test | Where we stand |
|---|---|
| Children's Product Certificate | We cannot issue it and neither can any other supplier. It is the importer's under 16 CFR 1110.7. We pass through accredited third-party test reports in the testing laboratory's name, which is what the certificate rests on. Our previous claim to provide "compliance documentation" was loose and is withdrawn |
| eFiling into ACE | Your obligation, live since 8 July 2026. We can supply the underlying data elements; we are not the filer |
| Lead testing scope | We test hardware, coatings and print — the components the recall record actually implicates and that 1500.91(d)(7) does not exempt. Ask us for the component-level reports, not a single bag-level certificate |
| EN 71 | We should not have claimed it and no longer do. We can commission EN 71-3 migration testing on request; it is not a legal requirement for a non-toy bag |
| CE marking | We will not CE-mark a backpack, and you should decline any supplier who offers to |
| EU responsible person | We are not established in the Union and cannot be yours. Without one you cannot lawfully place the goods on the EU market. This is the gap most likely to stop an EU-facing programme, and it is not one a supplier can close for you |
| DIN 58124 | We can build to the 20% fluorescent and 10% retroreflective requirement. We do not hold a conformity assessment against the standard, and we will not print "entspricht DIN 58124" without one |
| Tracking labels | We apply sewn-in woven labels carrying manufacturer or private labeler, location and date of production and a cohort code. Confirm the packaging mark separately — it is required too and is easy to miss |
| Pricing and minimums | Withdrawn as unsourced. Current terms are 100 units per style branded and 50 for catalogue stock, self-reported and unaudited |
Six of these nine record something we cannot do, cannot hold, or previously claimed wrongly.
If you are scoping a daycare, camp or youth programme, send the age range you are dressing, the destination markets, and whether the bag will be marketed as a children's product or a general use one — that last answer changes your obligations more than any spec line. You can see current silhouettes in the kids and school collections, stock-priced items in bulk deals, and you can ask for a quote here.
Related reading. For school-programme compliance more broadly, see the school backpack buying guide. For decoration methods and the lead question on inks, see logo printing methods. For the duty stack and the ruling record, the team sports guide, and for freight and customs, shipping, freight and customs.
What we could not verify
- No published price benchmark exists for decorated children's backpacks. This is a well-searched null result, not a failure to look — the search is described above. Our deleted ranges cannot be checked, and neither can anyone else's.
- We did not obtain an average unit value for HTS 4202.92.3120. USITC DataWeb requires an account and the Census trade API requires a key. The method is stated above so you can run it yourself; we are not printing a number we could not pull.
- CPSC's full FAQ answer on textile screen-printing inks as a surface coating could not be retrieved — the page serves collapsed accordions. The 1303.2(b)(1) exclusion for inks that become part of the substrate is solid; the edge case of a plastisol film sitting on top of the fabric is not resolved, and it is the case most relevant to a printed kids bag.
- The small-parts cylinder minimum depth is unverified. Figure 1 to 16 CFR 1501.4 is an image in every official source we could reach. The 1.25 inch diameter and 2.25 inch maximum depth are CPSC-sourced; the commonly quoted 1.0 inch minimum is not, so we have not printed it.
- Whether a toddler backpack is an exempt "accessory" under 16 CFR 1501.3 is not settled by the text. The exemption covers "Children's clothing and accessories, such as shoe lace holders and buttons", and the examples read like garment trim. We are not asserting either way. The practical risk sits in detachable zip pulls, charms, appliqués and eyes regardless of how the shell is classified.
- DIN 58124's normative text is paywalled. The 20% and 10% figures, the measurement angles and the colour change come from DIN's own published summary and from KAN, not from the standard clause by clause. We have not printed an exhaustive list of permitted colours because we could not confirm one. Likewise we infer, but could not confirm from the standard, that it sets no empty-weight cap.
- Regulation (EU) 2025/2509 Annex I was not read item by item. We confirmed the new Toy Safety Regulation carries the same Article 2 scope formula and applies from 1 August 2030, and we are inferring with high confidence — but not verification — that the "fashion accessories" exclusion carries across.
- No CPSC guidance addresses hybrid toy and non-toy articles such as a plush-fronted backpack. Our reading applies the F963 "plaything" definition and the EU guidance; it is not a cited agency position on the US side.
- We did not confirm current EU or UK duty rates from a primary source. The UK Trade Tariff is an interactive service and the EU combined nomenclature pages were not retrievable. No rate is printed.
- Chapter 99 additional duty rates move constantly. The Section 301 and reciprocal-tariff figures that appear in older rulings are not current and we have not restated them here. Have your broker confirm the stack against your entry date.
- Our own status is self-reported. Everything in the table above is what we know about ourselves today, and every line can be evidenced on request.
Sources
US scope and substances. 15 U.S.C. 2052(a)(2); 16 CFR 1200.2. 15 U.S.C. 1278a; 16 CFR 1500.87; 16 CFR 1303.1 and 1303.2(b)(1); 16 CFR 1500.91(c) and (d)(7). 16 CFR 1307.1, 1307.2 and 1307.3. 16 CFR 1500.18(a)(9) and part 1501; 16 CFR 1501.3 and 1501.4. 16 CFR 1250.2 incorporating ASTM F963-23. CPSC 2020 Age Determination Guidelines.
Certification and labelling. 16 CFR 1110.7, 1110.11 and 1110.13; final rule "Certificates of Compliance", 90 FR 1800, 8 January 2025, with the correction of 24 September 2025; CPSC news release on eFiling, 8 July 2026. 15 U.S.C. 2063(a)(5); CPSC Tracking Labels FAQ.
Rules that do not apply. 16 CFR 1120.3(b) and the final rule at 76 FR, 19 July 2011; 16 CFR 1610.1; 16 CFR 1130.2; 16 CFR 1230 and ASTM F2549-22 for frame child carriers; 16 CFR 1226 and ASTM F2236 for soft carriers.
Recalls. CPSC recall numbers 22-731 (24 February 2022), 12-064 (22 December 2011), 08039 (23 October 2007), 98151 (18 August 1998), 93060 (2 April 1993), via the CPSC recall database.
EU and UK. Directive 2009/48/EC Articles 2, 10 and 13 and Annex I item 19; European Commission, Toy Safety Directive – An explanatory guidance document, Rev 1.7; EU Guidance Document No. 11. Regulation (EU) 2025/2509, OJ 12 December 2025, applying 1 August 2030. Regulation (EU) 2023/988 Article 16; Commission Notice C/2025/6233, 21 November 2025. Regulation (EC) 1907/2006 Annex XVII entries 23, 27, 43, 50, 51, 52 and 63. European Commission CE marking guidance. Regulation (EU) 2016/425 and EN 17353:2020. Toys (Safety) Regulations 2011 reg. 4 and Schedule 1 para. 20; General Product Safety Regulations 2005; UK OPSS guidance on EU 2023/988 in Northern Ireland. Council Regulation (EC) 1186/2009 Articles 21, 43-52 and 61-65; HMRC VAT Notice 714.
Visibility. DIN 58124:2018-10, Schulranzen — Anforderungen und Prüfung, via DIN's published summary and KAN. DGUV Information 202-109 and the DGUV Sichere Schule guidance for the empty-weight, body-weight and strap-width recommendations.
Tariff. USITC Harmonized Tariff Schedule, accessed 10 August 2026: 4202.12.21, .29, .40, .60, .81, .89; 4202.92.15, .20, .31, .45; expired 9902.12.37 through .45, subchapter II of chapter 99. CBP rulings NY N303113 (22 March 2019), NY N331692 (18 April 2023), HQ H307211 (18 August 2020), NY N360038 (14 April 2026), NY N347592 (17 April 2025), NY G87110, NY E84353, NY E81489, NY D80526, HQ 964449. USITC, Update to the HTS Basic Edition, on the lapse of GSP and the expiry of MTB suspensions.
Rewritten 10 August 2026. This page previously misstated the age CPSIA reaches, applied the phthalate rule to a product it does not cover, named EN 71 as a requirement when it is neither applicable nor mandatory, omitted the EU responsible-person obligation that decides market access, listed tracking-label content incompletely, and published prices and minimums with no source. It also implied we could supply a certificate that only an importer can issue. Corrections have been made in the open rather than quietly deleted. Certificate eFiling is already in force and the EU toy framework changes in 2030 — re-check anything here before it goes into a specification, a customs entry or a compliance file.
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