FAQ Safety Matters on Collector Diecast Model Cars.

Frequently Asked Questions: FAQ

1. What is CPSIA?
   CPSIA stands for the Consumer Product Safety Improvement Act.  It is a landmark United States federal law that President George W. Bush signed in 2008. Its primary goal was to increase the safety of consumer products, particularly those intended for children. This is the most critical component of the CPSIA. A "children's product" is defined as a consumer product designed or intended primarily for children 12 years of age or younger. Requirements for these products include:
   • Lead Limits: It established stricter limits on the amount of lead content allowed in children's products (in both paint/surface coatings and the substrate material).
   • Phthalate Bans: It permanently prohibited the use of certain phthalates (chemicals used to make plastics flexible) in children's toys.
   • Third-Party Testing: Manufacturers and importers of toys and children's products must have their products tested by a CPSC-accepted, third-party laboratory for safety compliance.
   • Children's Product Certificate (CPC): The manufacturer or importer must issue a written Children's Product Certificate (CPC)—the document you asked about previously—to certify, based on the third-party testing, that the product complies with all applicable safety rules.
   • Tracking Labels: All children's products must have permanent, distinguishing marks (tracking labels) affixed to them and their packaging. These labels must include the date and location on where the toy was manufactured, batch/run number, and source information to help with targeted recalls.
   
   
2. What is a CPC safety document?
   In the toy world, the term CPC safety document refers to the Children’s Product Certificate (CPC). What the Children’s Product Certificate (CPC) is:
   • A Certification: It is a written document in which the domestic manufacturer or importer certifies that their children's product complies with all applicable children's product safety rules, standards, and bans enforced by the Consumer Product Safety Commission (CPSC.)
   • Based on Testing: This certification must be based on passing test results from a CPSC-accepted, third-party laboratory.
   • Who Issues It: The domestic manufacturer (for toys or children’s products made in the US) or the importer (for toys or children’s products made overseas) is responsible for drafting and issuing the CPC.
   • Key Information Required on a CPC:
   • Product Identification: A detailed description of the product covered by the certificate.
   • Citation to Rules: A list of every applicable CPSC children's product safety rule (e.g., lead content limits, small parts ban, flammability standards) to which the product is being certified.
   • Manufacturer/Importer Information: Name, full mailing address, and telephone number of the certifying party.
   • Test Record Contact: Contact information for the individual who maintains records of the test results.
   • Manufacturing Dates and Location: The date(s) and place(s) where the product was manufactured.
   • Testing Dates and Location: The date(s) and place(s) where the product was tested for compliance.
   • Third-Party Lab Identification: The name, address, and contact information of the CPSC-accepted laboratory that conducted the testing
   • How Toy Wonders’ customers obtain a CPC:
   • CPSIA permits the distribution of CPC’s in electronic form and via the internet.
   • After an online order is shipped, our system will automatically generate an email with individual links any toys (i.e. intended primarily for children 12 years of age or younger) that were ordered, which will permit you to download the CPC.
   • Note that although we are called “Toy Wonders”, many skus we carry are NOT toys that meet CPSC’s definition of a toy (i.e. . intended primarily for children 12 years of age or younger).
   
   
3. What is a ASTM?
   ASTM stands for American Society for Testing and Materials. It is officially now known as ASTM International, reflecting its global reach in developing and publishing technical standards. ASTM International is one of the world's largest developers of voluntary consensus standards on all types of products (not just toys). These standards are used by industries, governments, and consumers worldwide to ensure the quality, safety, and reliability of materials, products, systems, and services.  Some key points to its role:
   • Standards Development: It creates and publishes specifications, test methods, guides, and practices that define how materials and products are tested and evaluated.
   • Voluntary Adoption: The standards are generally voluntary, but they are often incorporated into government regulations, building codes, and contracts, making compliance mandatory in those specific contexts.
   • Wide Scope: ASTM standards cover a vast range of industries, including:
   • Construction (e.g., steel, concrete)
   • Manufacturing (e.g., metals, plastics, textiles)
   • Consumer Products (e.g., the safety standard for toys, ASTM F963, which is mandatory under the CPSIA you asked about earlier)
   • Environment, Energy, and Transportation
     
   
   
4. What is ASTM F963?
   ASTM F963 is a standard for U.S. toy safety, which sets requirements for physical, chemical, and flammability standards to protect children. Compliance is mandatory for toys sold in the U.S. and requires third-party testing by a CPSC-accepted laboratory. Key aspects of ASTM F963:
   • Children's Product Certificate (CPC): A CPC must be produced for each batch of compliant toys. This certificate includes details about the product, the safety rules it meets, and the testing laboratory used.
   • Hazard-Specific Requirements: The standard covers a wide range of potential dangers, including:
   • Chemical: Limits on lead, mercury, and other heavy metals in materials, as well as requirements for paints and coatings.
   • Physical: Requirements to prevent choking hazards, sharp edges, and other mechanical risks.
   • Flammability: Performance requirements to ensure toys do not pose a flammability risk.
   • Labeling and Instructions: The standard includes requirements for warning labels on packaging and instructional literature. 
   
   
5. Are collector diecast model cars toys?
   You would think this question would be an easy YES or NO answer, but unfortunately it’s not. This subject warrants detailed elaboration and requires an understanding on how the Consumer Product Safety Commission (not Oxford Languages or Merriam-Webster) defines the word “toy” and “age appropriateness”. Though we probably can all agree that a “Bag O’ Glass” (made famous by skits performed by Dan Aykroyd on SNL) is not appropriate toy for any age group, understanding this particular this subject requires an understanding of the four principles the commission uses in age grading (i.e. what toys and children’s products are appropriate for what age group).

   
   Age-Grading is not a science and subject to human subjectivity, which can result in different conclusions based on the person doing the analysis. When retailers are unsure if a product is a toy or not, for them it’s safer for them to classify it as a product designed for children under the ages of twelve. This matter has been an endless source of frustration to people in the collector diecast model car business because the financial and time resources required to meet mandates in CPSIA is significant for an industry that operates on very thin margins. My family has been distributing toys for 3 generations, and I have in the industry long enough to remember that the CPSC (i.e. the commission itself) was NOT in favor for the passage of CPSIA; Unbeknownst to the congressmen, senator, and President George Bush in 2008 their passage of CPSIA would cause unintended consequences.  One immediate cause was that numerous small cottage toy manufacturers, importers, and distributors who made or distributed small batch run of toys to go out of business. Afterall, which elected official would dare to vote against safer toys for our children? With supply and unique innovative toys this particular industry provided going out of business, this in turn would have the end result of putting out of business every mom and pop store on main street and eventually every regional and national toy store. As these specialty retailers attempted to adopt the same mass-market items the big box stores offered, they quickly found they were not competitive.  Because the collector diecast model car industry is also characterized by small batch runs and often limited editions, so you can understand my deep concern in having our entire product line classified as a child’s product and therefore within the scope of CPSIA. This is why I am spending time to write about this subject and maybe it can serve to stop the mis-classification of age appropriateness of diecast cars collector cars.

    

   First of all, let’s start with a couple facts.  There are diecast model cars designed primarily for children under the ages of 12 and therefore considered “toys” and subject to the rules and regulations of CPSIA.  Conversely, there are diecast model cars that are NOT designed primarily for children under the ages of 12 and are thus not subject to the rules and regulations of CPSIA.  I am making groupings based on scale, as this is how our industry usually markets diecast model cars.  Although there is a positive correlation between scale and age appropriateness, the CPSC in their guidelines does NOT attempt to define what IS (or IS NOT) based on its size (or in our terminology, scale). Based on my 33+ years in marketing toys and collector diecast toy cars and my understanding of CPSIA, ASTM F963, CPSC’ Age Determination Guidelines, and their many references to different titles of the Code of Federal Regulations (CRF) and particularly Title 16 which deal with Commercial Practices, and what new rulings that I can find that the Commission has made that pertain to diecast model cars, these are my conclusions on the matter:

    

   • Are 1/18 scale diecast cars toys?
   • Are 1/24 scale diecast cars toys?
   • Are 1/36 to 1/43 scale diecast cars toys?
   • Are 1/64 scale diecast cars toys?
   
   Helpulf Links pertaining to toy safety:
   
   CPSC's (Consumer Product Safety Commission) general web site
   
   CPSIA (Consumer Product Safety Improvement Act)
   
   ASTMF963
   
   CPSC Age Determination Guidelines
   
   Code of Federal Regulations
   
   What are the Phthalates?
   
   Product Recall Information (updated regularly)