Which rules apply to shape sorters
- Shape sorters test the defining feature — the sorting lid and shape pieces — for small-parts fit (shapes must not fit the small-parts cylinder if graded under 3), lead in wood and painted shapes, and box integrity after abuse.
- CPSIA section 101 total lead content in accessible substrate materials.
- 16 CFR part 1303 lead in paint and surface coatings where painted or coated.
- CPSIA section 103 tracking labels: manufacturer, location, and date of manufacture on product and packaging.
The testing and certification path
Testing covers each shape against the small-parts cylinder (for under-3 grading, shapes must be too large), lead in wood substrates and painted shapes, hinge and lid integrity, and interior accessibility so stuck shapes can be retrieved without breaking the box.
Book testing at a laboratory that is CPSC-accepted for each rule, issue the CPC in your own name citing the rules your report supports, and keep the certificate with its test report for at least five years. Marketplaces ask for the pair, not the certificate alone.
Questions people ask
What if my sorter shapes are naturally small?
Then the product cannot be honestly graded under 3 — grade it 12 months+ only if shapes pass the cylinder. Under-3 sorting toys use deliberately oversized shapes.
Do wooden sorters need coating tests?
Painted shapes test the coating for lead; natural wood tests the substrate. Every color and wood finish is a test line.
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