Handmade toys, soap and cosmetics rules

Handmade children's products need third-party testing and a certificate

If you make a product designed mainly for children 12 or younger, federal law requires a Children's Product Certificate based on testing by a CPSC-accepted third-party lab. Being handmade does not exempt it.

This catches crochet toy makers, baby clothing sellers and wooden toy makers more than anyone. The rule is about who the product is for, not how many you make or how you make them. A bib, a stuffed animal and a child's hair clip can all be children's products.

The certificate is your written statement that the product meets the safety rules that apply to it, backed by the lab results. As the domestic manufacturer, you are the one who issues it.

Domestic manufacturers and importers of children's products must issue a Children's Product Certificate based on test results from a third-party, CPSC-accepted laboratory. — U.S. Consumer Product Safety Commission, retrieved 2026-09-27

12 or youngerCPSC defines a children's product as a consumer product designed or intended primarily for children 12 years of age or younger. — U.S. Consumer Product Safety Commission, retrieved 2026-09-27

Small batch registration reduces testing for small makers

A maker with no more than $1,436,864 in prior-year gross revenue can register with CPSC as a small batch manufacturer, which relaxes some testing, for products made in runs of 7,500 units or fewer.

Registration is not automatic. You register on SaferProducts.gov, and the registration lasts only for the calendar year you register in, so it has to be renewed each year. Put it on the calendar next to your estimated tax dates.

The relief applies to what CPSC calls Group B requirements. For those, a registered small batch maker may use other means than a third-party lab, such as supplier assurances or its own testing, where those are available.

$1,436,864CPSC's small batch threshold is total gross revenue of $1,436,864 or less from the sale of all consumer products in the prior calendar year. — U.S. Consumer Product Safety Commission, retrieved 2026-09-27

7,500 unitsA product qualifies for small batch treatment when no more than 7,500 units of the same product were manufactured in the previous calendar year. — U.S. Consumer Product Safety Commission, retrieved 2026-09-27

Small batch registration on SaferProducts.gov is valid for the calendar year in which the manufacturer registers. — U.S. Consumer Product Safety Commission, retrieved 2026-09-27

Some children's product tests are never waived

Small batch status never removes the Group A requirements. Lead in paint, small parts and similar core safety rules always need third-party testing, however small the shop.

This is where handmade toy sellers most often get caught. Registering as a small batch maker feels like it solves the testing question, but the most common hazards for young children sit in the group that is never relaxed. A painted wooden toy or a stuffed animal with button eyes can fall squarely into it.

Before you list a children's product, work out which rules apply to it, which of those are Group A, and budget for lab testing of those. Testing is per product, so a wide range of designs costs more than a narrow one.

CPSC says small batch manufacturers are always required to third-party test for the children's product safety rules in Group A, such as lead in paint and small parts. — U.S. Consumer Product Safety Commission, retrieved 2026-09-27

True soap falls under CPSC, not FDA

A bar that meets FDA's definition of soap is regulated by CPSC, not by FDA. To qualify, it must be mainly alkali salts of fatty acids, clean only through those salts, and be sold only as soap.

That is the traditional cold-process or hot-process bar made from oils and lye, and labeled simply as soap. For many soap makers it is the lighter-touch category.

The definition is narrow, and marketing is where makers step out of it. The moment the label or listing promises more than cleaning, the product may no longer be soap in the regulatory sense.

FDA says a product is regulated as soap only if it is composed mainly of alkali salts of fatty acids, those salts are its only cleaning agent, and it is labeled and marketed only as soap. — U.S. Food and Drug Administration, retrieved 2026-09-27

Products that meet FDA's regulatory definition of soap are regulated by the Consumer Product Safety Commission. — U.S. Food and Drug Administration, retrieved 2026-09-27

Claims on the label can turn a soap into a cosmetic or a drug

A soap marketed to moisturize, scent or beautify is regulated as a cosmetic. One that claims to treat acne, eczema or kill germs is regulated as a drug. The label decides.

This matters for how you write listings. "Lavender soap" describes a product. "Lavender soap that soothes eczema" makes a drug claim. The second one brings drug rules into play, which a small soap maker is rarely set up to meet.

Keep product descriptions to what the item is and how it is used. If you want to sell lotions, balms or scrubs, plan for them as cosmetics from the start, with the labeling that requires.

FDA says a soap becomes a cosmetic when it carries claims such as moisturizing or fragrance, and a drug when it is intended to treat or prevent disease or skin conditions such as acne or eczema. — U.S. Food and Drug Administration, retrieved 2026-09-27

Handmade cosmetics need no FDA approval but must be labeled

Cosmetics, other than color additives, do not need FDA approval before sale. They must be safe and correctly labeled, including an ingredient list and a street address.

The address rule catches home-based makers. FDA requires the name and address of the manufacturer, packer or distributor on the label, and says a post office box or a website is not enough. If you do not want your home address on every jar, that is a practical reason to use a business address.

Under the 2022 cosmetics law, many facilities must register with FDA and list their products. Certain small businesses are exempt. The exemption does not cover products used near the eye, injected, taken internally or meant to alter appearance for more than 24 hours.

FDA says the law does not require cosmetic products and ingredients, other than color additives, to be approved by FDA before they go on the market. — U.S. Food and Drug Administration, retrieved 2026-09-27

FDA says a cosmetic label's manufacturer or distributor address must be a street address, and a post office box or website address is not adequate. — U.S. Food and Drug Administration, retrieved 2026-09-27

FDA says the small business exemption from registration and listing excludes products used on the eye's mucous membrane, injected, taken internally, or altering appearance over 24 hours. — U.S. Food and Drug Administration, retrieved 2026-09-27

Check your product line against these rules before listing

Sort each product into a bucket: children's product, true soap, cosmetic, or none of these. Each bucket has its own steps, and doing them before you list is far cheaper than after.

Children's products need a certificate, lab testing for Group A rules, and a decision on small batch registration. Cosmetics need a proper label and a check against the registration rules. Soap needs careful wording to stay soap.

These are also the product lines where insurance matters most, as the insurance page explains, and where an LLC starts to make sense sooner. Add the testing cost to the cost breakdown before pricing.

A Children's Product Certificate must be based on test results from a third-party, CPSC-accepted laboratory. — U.S. Consumer Product Safety Commission, retrieved 2026-09-27

Questions