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GUIDES

How to import Japanese goods into the US: CPSC, CPC and Prop 65 explained

By Rei Shirase · Tokyo Works · October 13, 2026

Rei prepares the proposals, invoices and compliance documents for Tokyo Works' wholesale customers. This guide is a practical summary, not legal advice. Rules change; confirm the current requirements with your customs broker or a CPSC-accepted laboratory before you ship.

You found a Japanese plush, blind-box figure or stationery line you want to sell in the United States. The maker is happy to supply. Then your customs broker asks: "Do you have the CPC?" This guide explains what that question means, which products need one, and what we do about it on our side.

1. First question: is it a "children's product"?

US federal law (the Consumer Product Safety Improvement Act, CPSIA) draws one line that decides almost everything: whether the product is a children's product, meaning a consumer product "designed or intended primarily for children 12 years of age or younger."

The Consumer Product Safety Commission (CPSC) does not take the maker's word for it. It looks at four things together:

  1. what the manufacturer says about intended use, including the label, if that statement is reasonable;
  2. how the product appears in packaging, display, promotion or advertising;
  3. whether consumers commonly recognize it as intended for a child 12 or younger;
  4. CPSC's own Age Determination Guidelines.

This matters for Japanese goods in particular. A large part of the character-goods market in Japan is bought by adults and collectors, and makers often age-grade a plush or figure "15+" for exactly that reason. A "15+" sticker helps, but it is not a free pass. If the item looks like a toy for a small child and is displayed next to toys, CPSC can still treat it as a children's product. The honest answer is sometimes "this will be judged as a children's product, so let's test it."

2. What a children's product has to meet

For the goods we handle (plush, figures, stationery, small accessories), the rules that come up most often are:

Requirement Limit / rule Applies to
Total lead content 100 ppm in any accessible component All children's products
Lead in paint and surface coatings 90 ppm (0.009 %) All children's products
Phthalates 0.1 % for each of 8 listed phthalates (DEHP, DBP, BBP, DINP, DIBP, DPENP, DHEXP, DCHP) in accessible plasticized parts Children's toys and child care articles
Toy safety standard ASTM F963-23 (mandatory under CPSIA section 106) Toys
Small parts Banned in toys and articles for children under 3 (16 CFR 1501); choking-hazard labeling for 3 to 6 Toys
Tracking label Permanent label on the product and its packaging showing the maker or importer, where and when it was made, and a batch or lot reference All children's products

A children's product must be tested for these rules by a CPSC-accepted third-party laboratory. The maker's own in-house test, or a Japanese ST-mark or European EN71 report, does not replace it, although a lab that holds those reports can often test faster.

3. The CPC: what it is and who signs it

A Children's Product Certificate (CPC) is the written certificate that says the product has been tested and complies. US law requires it from "domestic manufacturers and importers." When you buy from Japan, you are the importer, so the CPC is yours to issue, based on the lab reports. You do not need a government stamp; you need the test reports and a correctly written certificate.

A CPC has seven required parts:

  1. identification of the product, detailed enough to match the certificate to that product and no other;
  2. each applicable children's product safety rule, cited;
  3. the name, mailing address and telephone number of the importer (or manufacturer) issuing it;
  4. the contact who keeps the test records;
  5. the date (at least month and year) and place of manufacture;
  6. the date and place of the testing;
  7. the name, address and telephone number of the third-party laboratory.

New since July 8, 2026: eFiling. CPSC now requires certificate data for regulated imported products to be filed electronically when the shipment is entered. In practice your broker files it in CBP's ACE system, and you either give the broker the certificate data or register it in CPSC's Product Registry. Your broker will ask for it before arrival, not after. Have the CPC ready when the goods leave Japan.

4. Goods that are not children's products

Mugs, adult stationery, pouches, keychains and most "goods for fans" are general-use products. They do not need a CPC. A separate document, the General Certificate of Conformity (GCC), is required only when the product is covered by a specific CPSC rule, and third-party testing is not mandatory for a GCC. Most of our general-use lines need neither. They still have to be safe, and the age-grading question in section 1 still decides which side of the line they fall on.

5. Prop 65 is a different thing

California's Proposition 65 is a state law, not a CPSC rule. It requires businesses to give a "clear and reasonable warning" before exposing people in California to chemicals the state has listed as causing cancer or reproductive harm. The list is long and is updated at least once a year. For goods like ours the chemicals that come up are mostly lead and phthalates in plastics, coatings and vinyl.

Three practical points:

  • It is about warnings, not bans. A product can be legal to sell in California with a warning label.
  • Businesses with fewer than 10 employees are exempt from the warning requirement, but large retailers and marketplaces usually require the warning (or proof it is not needed) by contract, whatever your size.
  • A CPC does not cover Prop 65. The CPSC lead and phthalate tests do help, because the same reports show what is in the product.

Whether to label is your decision with your counsel. We supply the material information and test results you need to make it.

6. What Tokyo Works does on our side

When you send us details of the toys you want to carry in the US, we answer with one of the three outcomes below and tell you clearly which one applies:

  1. Reports exist. The maker (or a previous US importer with their consent) already has CPSC-accepted lab reports. We obtain them and prepare a CPC draft in your name for you to check and sign.
  2. Testing is needed. We arrange testing at a CPSC-accepted laboratory, or ask the maker to have the product tested. We agree the samples, scope and timing with you before anything is sent, and prepare the CPC from the results.
  3. It is a general-use product. We say so, explain why (age grading, how it is sold in Japan), and flag any item we think a US buyer would still read as a children's product.

We also ask the factory for the tracking-label information (maker, production month, lot) early, because that has to be printed before production, not after.

7. Checklist before you place the order

  • ☐ Is the product a children's product under the four factors? Decide this first.
  • ☐ Which rules apply (lead, paint, phthalates, ASTM F963, small parts)?
  • ☐ Do CPSC-accepted lab reports exist for this exact item and version?
  • ☐ Who issues the CPC (you, as importer) and who keeps the records?
  • ☐ Is the tracking label on the product and the packaging?
  • ☐ Does your broker have the certificate data for eFiling before arrival?
  • ☐ Will the product be sold in California? Decide on Prop 65 warnings.

If you are not sure about an item, send us the product and we will tell you which of the three answers applies.

Tokyo Works · rei@tokyoworksjp.com

Sources (official)

Send us details of the toys you want to carry in the US. We will tell you which of the three outcomes applies.

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