TikTok Shop published its monthly Policy Pulse digest on July 10, 2026, summarizing a batch of seller-facing policy changes that took effect across June, the most consequential of which folds a federal customs rule directly into the platform’s own compliance guidance. Among updates covering tracking fraud, listing consistency, delivery metrics, and buyer refunds, TikTok Shop told US sellers that products requiring a Children’s Product Certificate or a General Certificate of Conformity under U.S. Consumer Product Safety Commission rules……Continue reading….
By: Luis Rijo
Source: PPC Land
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Critics:
CPC law defines a “children’s product” as a consumer product designed or intended primarily for children 12 years of age or younger. In determining whether a consumer product is primarily intended for a child 12 years of age or younger, the following factors will be considered:
- A statement by the manufacturer about the intended use of the product, including a label on the product, if such statement is reasonable.
- Whether the product is represented in its packaging, display, promotion, or advertising as appropriate for use by children 12 years of age or younger.
- Whether the product is commonly recognized by consumers as being intended for use by a child 12 years of age or younger.
- The Age Determination Guidelines issued by the Commission staff in September 2002, and any successor to such guidelines.
As of February 10, 2009, it shall be unlawful for any person to manufacture for sale, distribute in commerce, or import any children’s toy or childcare article that contains the phthalates DEHP, DBP, or BBP at levels higher than 0.1 percent.
The legislation bans from any children’s toy that can be put in a child’s mouth or childcare articles phthalates DINP, DIDP, and DnOP at levels higher than 0.1% on an interim basis until a report from the Chronic Hazard Advisory Panel (CHAP) is received, after which the CPSC can continue the prohibition by rule.
CPSC General Counsel Falvey provided an advisory opinion on October 17, 2008 that the phthalate ban does not apply to children’s footwear. Falvey provided an additional opinion on November 17, 2008 that the ban does not apply to wearing apparel, but does apply to toy costumes, bibs, sleepwear.
Notably in its distinction from the lead ruling of September 12, 2008, the phthalate ban will apply to articles manufactured on or after February 10, 2009. However, the decision was challenged by the Natural Resources Defense Council (NRDC) and Public Citizen in the New York Southern District Court and set aside by Judge Paul Gardephe on February 5, 2009.
The law defines a “children’s product” as a consumer product designed or intended primarily for children 12 years of age or younger. In determining whether a consumer product is primarily intended for a child 12 years of age or younger, the following factors will be considered:
As of February 10, 2009, it shall be unlawful for any person to manufacture for sale, distribute in commerce, or import any children’s toy or childcare article that contains the phthalates DEHP, DBP, or BBP at levels higher than 0.1 percent.
The legislation bans from any children’s toy that can be put in a child’s mouth or childcare articles phthalates DINP, DIDP, and DnOP at levels higher than 0.1% on an interim basis until a report from the Chronic Hazard Advisory Panel (CHAP) is received, after which the CPSC can continue the prohibition by rule.
CPSC General Counsel Falvey provided an advisory opinion on October 17, 2008 that the phthalate ban does not apply to children’s footwear. Falvey provided an additional opinion on November 17, 2008 that the ban does not apply to wearing apparel, but does apply to toy costumes, bibs, sleepwear. Notably in its distinction from the lead ruling of September 12, 2008, the phthalate ban will apply to articles manufactured on or after February 10, 2009.
However, the decision was challenged by the Natural Resources Defense Council (NRDC) and Public Citizen in the New York Southern District Court and set aside by Judge Paul Gardephe on February 5, 2009. Manufacturers pointed out that many of the products to be impacted were already making their way through the supply chain. As a result, much inventory that was legal prior to the signing of the law and was manufactured shortly thereafter were probably already on shelves as the deadlines approached.
The Natural Resources Defense Council and Public Citizen apparently agreed that these products were already in distribution, but believed that manufacturers should still be held liable. The problem was not the lead or phthalate content, as they imply, but the fact that the products must be tested to make sure they comply. There was also confusion of what products need a GCC and which do not.
They had not been tested because the items generally do not contain hazardous materials; CPSC had been slow to define some of the accreditation or testing criteria; some of the low volume, low value items were not economical to test; and lot tracking methods would not allow some of the items to be tracked. Manufacturers also point out that even if they attempted to comply, there are logistical problems.
Companies with large varieties of products will have difficulty selecting several samples of every item. Even if they can, there are not enough testing facilities to handle the volume in time to meet the schedules. Manufacturers also note both the difficulty and the apparently contradictory mandate to perform unit testing.
An apparel manufacturer, for example, might use a single mill product such as organic cotton cloth coupled with a few organic dyes and a few pieces of hardware such as zippers or buttons. Those can be combined in limitless ways and in various sizes. Testing all of the final products generally provides no more information than would testing the individual inputs (or “components”), but is vastly more expensive.
In response to this criticism, the CPSC added Rule 1109, known as the “Component Part Testing Rule”, that allows U.S. importers to rely on suppliers to meet testing requirements, so long as “due care” is used to make sure that the supplier has in fact complied with requirements.
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