Bag Regulations and Labeling Rules in the United States: An Overview

Are you thinking about importing bags to the United States? If so, here is a useful guide on applicable bag regulations in the United States.

Mentioned Products

• Leather bags
• Wallets
• Handbags
• Backpacks
• Children’s Backpacks

California Proposition 65

California Proposition 65 sets restrictions on over 800 chemicals and heavy metals in all consumer products sold in California, including bag products.

Therefore, bags and other consumer products (e.g. wallets, luggage, and accessories) that contain excessive amounts (e.g. above the max limits) cannot be sold in California.

Examples of restricted substances

• Lead
• Cadmium
• Mercury
• Phthalates

Risks

Certain types of heavy metals and phthalates are present in leather, PU leather, and coatings. Further, hardware parts (e.g. zippers, buttons, and ornaments) may contain excessive amounts of lead, cadmium and other heavy metals.

Warning Labeling

California Proposition 65 third-party testing is an alternative if you don’t want to attach a warning label to your bags or their packaging. However, in this case, you must prove that your product has been tested by third-party testing companies.

California Proposition 65 Lab testing

It is strongly recommended that you conduct lab testing on your products (eg. handbags, school bags) before your importing to the US market. Since it is the only way to verify whether your products meet the compliant requirements with California Proposition 65.

Additionally, It’s important to bear in mind that most Asian bags manufacturers and traders cannot offer California 65 testing reports. You may have to look for the equivalent lab testing party to conduct the tests.

Testing costs

The cost of conducting a California Proposition 65 third-party lab testing depends on the quantities, materials, and colors of your bags. It ranges from $200 to an unlimited amount based on the previously mentioned factors.

Testing companies

Click here for an overview of companies offering California Proposition 65 lab testing services.

CPSIA: Children’s Bags

CPSIA is a regulation regarding children’s products sold in the US market. Bags that are targeted to 12 years old or less in the US market are regulated under CPSIA.

ASTM Standards

CPSIA requires that your children’s bags, luggage, backpacks other children’s products are fully compliant with all applicable ASTM standards, substance restrictions (e.g. lead and cadmium), and other rules.

Examples

• ASTM F963-17 – Surface Coating Materials – Soluble Test for Metals
• ASTM F963-17 – Stuffing Materials
• ASTM F963-17 – Magnets
• ASTM F963-16 – Small Objects

Learn more

You can learn more about relevant ASTM standards and rules on this page.

CPSIA Testing

CPSIA requires importers to provide lab testing reports when importing and selling children’s bags in the US market. A testing report is not valid unless it is within CPSC’s approved testing companies.

It is important to keep in mind that the tested samples must be drawn from the production batch. Test reports will not be recognized if they are conducted on different samples.

A list of applicable ASTM and CPSC standards can also be obtained from CPSC testing companies. Generally, it is for free to request a quotation.

List of CPSC approved testing companies

• Bureau Veritas
• QIMA
• SGS
• TUV
• Intertek

Click here for information on more CPSC approved testing companies.

CPSIA Testing Costs

The cost of the CPSIA lab testing report starts from around $300 per product. However, the price ultimately depends on the quantity of the products, applicable standards, materials, colors and so on.

Learn more

You can read more about CPSIA and ASTM lab testing in this guide.

Children’s Product Certificate (CPC)

CPC (Children’s Product Certificate) is a mandatory document to provide for children’s bags’ importers. It is a self-issued document with key information about your products, eg: company name, supplier location, applicable standards, and information on the CPSC approved testing company.

Content Summary

1. Product name and description

2. List of applied and mandatory ASTM and CPSC standards (e.g ASTM F963)

3. Importer information (name, address, e-mail, phone)

4. Contact information of the person with access to the test report (name, address, e-mail, phone)

5. Manufacturing location (city, province, country) and date (month, year)

6. Testing date (month, year) and location (city, province, country)

7. CPSC accepted third-party lab testing company (company, contact person, address, phone, e-mail)

Learn more

This guide explains how to create a CPC when importing children’s bags and other children’s products.

CPSIA Tracking Label

Your products must carry a CPSIA tracking label. Here is an overview of the information it must include:

• Importer/company name
• Place of production
• Date of manufacture
• Batch number

Example

• Kid’s Backpacks Online LLC
• Place of production: Xiamen, Fujian, China
• Date of manufacture: September 2019
• Batch Number: BP01-0919-XM-CN1

Label file

You should create the tracking labels for the bag on your own because it is not included in the suppliers’ services or area or expertise for that matter. The tracking label should be in the appropriate format with all the required information. In addition, you must also include the following information in your tracking labels:

• Print position
• Dimensions
• Colors
• Print type

Country of Origin

A COO (Country of Origin label) is obligatory to be attached on most of the products in the US market, including handbags, backpacks and other related products. The product and the packaging must have a permanently affixed country of origin label. A product packing is not appropriate and qualified with merely stickers on.

Examples

• Made in China
• Made in Thailand
• Made in Singapore
• Made in Italy

Label file

Before you start producing, make sure to create a file for Country of Origin and send it to your manufacturer. This is an essential step to keep track of your file and for future references. We recommend you save the files in .ai or .eps formats for compatibility reason.

Textiles Labeling

It is obligatory for textile bags imported to or manufactured in the US carrying a permanent (e.g. nylon patch or printed) textiles label, in order to present fiber composition and care instructions of the contents. This requirement is also applied to bag products.

Label Information

• Importer or manufacturer information
• Fiber composition (e.g. 100% cotton)
• ASTM care labels (link)
• English language

Label file

Before you start producing, make sure to create a file for your labels and share them with your manufacturer. This is an essential step to keep track of your file and for future references. As already mentioned in the country of origin section, we recommend you save the files in .ai or .eps formats for compatibility reason.

Leather Regulations

The FTC leather labeling guide (Link) states that bag importers, manufacturers, and sellers must specify if the product is made of imitation leather (e.g. PU leather). Further, you cannot make false claims about the leather type or quality.

Note: Note that regulations restricting chemicals and heavy metals (e.g. CPSIA and CA Prop 65) also apply to leather products.

ASTM Standards

Even if compliance with ASTM standards is generally not compulsory, manufacturers and importers often use ASTM standards during the product development stage to ensure the safety and quality of the product. Further, ASTM standards also offer reliable quality testing methods and procedures, covering various aspects relevant for bags:

• Color testing and performance
• Material testing and performance
• Physical and mechanical properties (e.g. bag seams)
• Capacity testing

Note: Unsafe products are subject to forced recall. Always keep in mind that products that contain excessive toxic contents are at great risks of forced recall. This also applies to products that do not require safety tests. Therefore, it is in the interests of all the parties involved to ensure the safety of the products at all times.

Examples of ASTM standards for bags

• ASTM D5552-10 – Standard Test Method for Resistance of Colored Leather to Bleeding
• F2153-07 – Standard Test Method for Measurement of Backpack Capacity

More information on ASTM standards could be found on their official website.

ASTM testing

SGS, Intertek, QIMA, Bureau Veritas, and other established third-party testing companies offer ASTM lab testing services. In China, Vietnam and most of the South East Asian countries, bag manufacturers usually do not have the in-house expertise and equipment to practice ASTM testing.

Product Packaging

Bags, backpack, and luggage importers and manufacturers must also ensure that the packaging materials are compliant. Below follows a brief summary of US packaging requirements.

Heavy Metals Restrictions

Many US states restrict lead, cadmium, mercury, and other heavy metals in packaging materials, printing inks, and dyes. Third-party lab testing is the only available method to verify if your packaging materials are compliant.

Intertek, SGS, TUV, QIMA and other product testing companies offer packaging materials testing services.

Labeling Requirements

Product labeling requirements, such as country of origin and compliance marks, may also need to be printed on the product packaging.

Amazon Compliance Requirements

Products sold on Amazon.com must comply with all mandatory United States product safety standards, certification, and labeling requirements. Amazon also has a history of forcing third-party sellers to comply with standards that are otherwise voluntary.

It’s therefore essential that you carefully read the relevant product category requirements in the Amazon Seller Central before you intend to import and sell handbags, backpacks, and other bags.

How does Amazon check product compliance?

Amazon may request lab test reports, certificates, product photos, and invoices when listing new SKUs. They may also contact you to request these files if they have any reason to review your product.

What can happen if we sell non-compliant bags on Amazon?

Amazon has the right to remove your product listing. In most cases we have seen, Amazon limits its action to specific SKUs. That said, they have the right to suspend all your product listings or your entire account. Still, bags, backpacks, and other related products for adults (e.g. not within the scope of CPSIA) are generally not considered as ‘high-risk products’.