Getting started

From bench to shelf

Updated October 2026

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Settle the audience first Then get the supply chain evidence Then size the pack Then choose the container Then the marks Then the certificate Why this order References

Findings are bought, not formulated, so the first real decision is who the pack is for.

Settle the audience first

Before the jar, before the label, before the case pack. The audience decides whether you are in the children’s product regime at all, and everything downstream is cheaper to get right than to unwind. A pack presented to bench jewelers and craft retailers is a component. A pack presented as a kit for children is a children’s product.

Then get the supply chain evidence

If you are on the children’s side, the lead content limit applies to any part of the product by weight, which means plating, base metal, solder and any coating. Ask for test reports from the people who made the part, and understand that a supplier certificate is not the same as a certificate issued on third party testing of your product.

Then size the pack

Findings are counted, not poured, so the pack size is a count and the container follows from it. A clasp pack of 20 and a jump ring pack of 500 are different containers even though both are small parts in a clear jar.

Then choose the container

Wide mouth so fingers and tweezers reach the bottom, clear so the count can be eyeballed, and a closure that survives repeated opening at a bench. Our shelf here is 224 containers from 22 to 500 mL with 257 closures, plus 39 more below 60 mL.

Then the marks

A children’s product carries permanent distinguishing marks on the product and its packaging to the extent practicable. Deciding that after the labels are printed is how a run gets reprinted.

Then the certificate

Samples to an accredited third party conformity assessment body, and a certificate issued on the basis of that testing, before importing or distributing in commerce. Either a separate certificate per applicable rule or a combined certificate that specifies each rule.

Why this order

Because the audience decision is free at the start and expensive at the end. Reversing it means new artwork, new photography, retesting, and in the worst case stock that cannot be sold as labeled.

References

15 U.S.C. 2052(a)(2), the Consumer Product Safety Act definitions as amended by the CPSIA. A children’s product is a consumer product designed or intended primarily for children 12 years of age or younger, determined by four factors: a manufacturer statement including a label if reasonable; representation in packaging, display, promotion or advertising; common recognition by consumers; and the Commission staff’s September 2002 Age Determination Guidelines. law.cornell.edu

15 U.S.C. 1278a, Children’s products containing lead; lead paint rule. Total lead content by weight for any part of the product: 600 ppm, then 300 ppm one year after 14 August 2008, then 100 ppm three years after, unless the Commission determines 100 ppm is not technologically feasible for a product or category. The Commission is to review and revise the limit downward periodically. law.cornell.edu

15 U.S.C. 2063, Product certification and labeling. Subsection (a)(2) requires a manufacturer or private labeler of a children’s product subject to a children’s product safety rule to submit sufficient samples to an accredited third party conformity assessment body and to issue a certificate based on that testing. Subsection (a)(5)(A) requires permanent distinguishing marks on the product and its packaging, to the extent practicable, identifying location and date of production and cohort information. law.cornell.edu

Written from the CPSIA and the CPSC regulations, not from a bench. Whether a particular product is a children’s product is a determination on the facts of that product, and state law in this area has not been surveyed here. Nothing on these pages is advice on a specific item.