Children's Clothing Import Checklist
Updated July 8, 2026 · For baby and children's apparel entering the United States
Use this before the commercial invoice is finalized, not after the container is on the water.
What changed July 8, 2026: Children's Product Certificate (CPC) data must now be filed electronically in ACE at entry through the CPSC PGA Message Set. The CPC itself, third-party testing, and CPSIA tracking labels are not new. No rule requires a sewn-in barcode.
1. Confirm product scope
- Age range for each style confirmed (newborn, infant, toddler, children under 12).
- Garment type identified: daywear, sleepwear, outerwear, costume, accessory, or textile article.
- Material composition confirmed by style: cotton, wool, synthetic/man-made fiber, blends, trims.
- Hazards flagged: small parts, snaps/buttons, drawstrings, coatings/prints, sleepwear, plasticized components.
- SKU/style/color/size matrix finalized before testing and certificate creation.
2. Testing and certificate file
| Item | What to confirm before shipment |
|---|
| Third-party lab | CPSC-accepted laboratory used for all required children's-product tests. |
| Textile flammability | 16 CFR Part 1610 evaluated for general wearing apparel. |
| Sleepwear | If sleepwear, evaluate 16 CFR Parts 1615/1616 before production ships. |
| Lead limits | 100 ppm substrate limit and 90 ppm surface-coating limit evaluated where relevant. |
| Small parts | 16 CFR Part 1501 reviewed for products intended for children under three. |
| Drawstrings | 16 CFR Part 1120 reviewed for children's upper outerwear. |
| Phthalates | 16 CFR Part 1307 reviewed only for plasticized components, not ordinary fabric. |
| CPC owner | Importer or domestic private labeler identified as the CPC issuer; factory certificate is not enough. |
3. CPSC eFiling data elements
Prepare these before the customs entry is transmitted. Your broker needs them in the correct structure for ACE.
- Product identifier: GTIN, UPC, SKU, model, or style number for each certified item.
- Each CPSC safety rule cited on the CPC.
- Date of manufacture for the certified goods.
- Place of manufacture: factory name, address, and contact details.
- Date and place of testing.
- CPSC-accepted laboratory name, address, contact details, and report reference.
- Certifier identity: name, address, email, and phone for the importer or domestic private labeler.
4. Labels and importer documents
Garment label checks
- Permanent CPSIA tracking label with manufacturer/private labeler, production place/date, and batch/run data.
- No barcode assumed required unless your own inventory system requires it.
- FTC fiber-content, country-of-origin, and care-label requirements reviewed.
- CBP country-of-origin marking consistent with invoice, packing list, and garment label.
Importer setup
- Importer of record chosen: brand, third-party IOR, or other responsible party.
- CPC owner chosen separately from IOR if using a third-party IOR.
- CBP Form 5106 / importer number ready if your company is the IOR.
- Customs bond and power of attorney ready before arrival.
5. Classification, duty, and timing
- HTS Chapter 61 (knit) or 62 (woven) classification reviewed line by line.
- Fiber-dependent base duty modeled: cotton lines commonly around 8%–16%; synthetic/man-made-fiber lines can reach roughly 32%.
- China-origin garments checked for Section 301 List 4A (+7.5%).
- Temporary Section 122 surcharge (+10%) checked for entries through July 24, 2026.
- IEEPA China layer not treated as current duty; struck down on Feb. 20, 2026 and handled through refund review if paid previously.
- Testing schedule built into production timeline before the bulk shipment sails.
- If considering an FTZ, confirm it is a timing strategy only; CPSC eFiling is still required when goods leave the zone for U.S. commerce.
6. Send this package to your broker
- Commercial invoice and packing list.
- Style/SKU matrix with sizes, colors, fabrics, trims, and intended age range.
- Lab reports and draft CPC for each style or product family.
- Label artwork or photos showing tracking label, care label, fiber content, and country of origin.
- Factory address and production dates.
- Importer-of-record decision and bond/POA setup status.
- Expected ship date, arrival date, port, and entry type.