What goes wrong

Assortment packs multiply the questions

Updated October 2026

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The failure Why it happens The colored items are a second question And the audience question gets harder What to do instead If you keep the assortment References

A mixed assortment is as many compliance questions as it has distinct parts.

The failure

A 500 piece mixed findings assortment is assembled from eight suppliers, tested as a single product, and certified. One of the eight changed a plating bath. The certificate covered samples that are no longer identical in all material respects to what is in the jar.

Why it happens

Because an assortment feels like one SKU. It has one barcode, one label and one price. For the lead content limit it is a set of parts, and the limit reads on any part of the product.

The colored items are a second question

Painted or coated pieces sit under the 0.009 percent coating limit as well as the content limit, and those are different measurements on different samples. Count the coated items in the assortment before planning any testing, because that count is the number of extra questions you just bought.

And the audience question gets harder

Mixed bright assortments photograph well and photograph young. An assortment pack can drift across the children’s product line through nothing but marketing imagery, with no change to a single part in it.

What to do instead

Keep assortments to parts from a controlled set of suppliers with change notification, or sell single part packs where each pack has one answer. Single part packs also count faster, pick faster and return less, which is the kind of reason that survives a change of ownership.

If you keep the assortment

Write down the bill of materials for it, by supplier and part, and treat a supplier substitution as a new product rather than a purchasing detail. The certificate is only as good as the sameness it assumes.

References

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

16 CFR 1303.1, Scope and application. Paint and similar surface coatings containing lead above 0.009 percent of the weight of the total nonvolatile content or the dried paint film are banned hazardous products, the limit having been reduced from 0.06 percent effective 14 August 2009 as mandated by section 101(f) of the CPSIA. Toys and other articles intended for use by children bearing such coatings are banned hazardous products. ecfr.gov

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.