Penn. Plush Toy Registration: What Changed and Why It Matters
Pennsylvania plush toy registration now requires flammability and tolerance testing reports in order sell certain types of plush and stuffed products in the state. These reports are required in addition to the required testing you do at your factory.
The rule took effect August 27, 2024. Ohio and Massachusetts also enacted laws for similar products. If you sell plush toys or other filled goods like bedding in these states, you must register your products in these states and use a compliant law label. You do not need these additional test results if you're not selling your products in these states, however, if you're selling online and do not want to exclude orders received from these states, you'll need these certifications.
At Klugonyx, we have already seen product launches delayed because teams were not aware of these relatively new state rules.
What Products Must Comply?
If your product contains filling and is sold as new, assume state rules apply in PA, OH, and MA. This includes plush toys, pillows, pet beds, bean bags, and upholstered children’s items.
What to File In Pennsylvania?
- Registration application with manufacturer or importer details
- Law label that lists ALL NEW MATERIAL and the PA Registration Number
- Lab reports for flammability and tolerance from a U.S. or CPSC-accredited lab
- Sterilization permit if you use natural fills like feathers or wool
Ohio and Massachusetts
- Massachusetts requires a state license and specific label wording under 105 CMR 620.
- Ohio requires registration through its Bedding and Upholstered Furniture program and prescribes label content.
Product Launch Timeline
Add about 3 weeks to your schedule for state approvals and any extra testing. You can sell outside these states while you wait. Do not ship into PA, OH, or MA until registration is active and labels match state rules.
Where to Test and Who Pays?
Use a CPSC-accredited or U.S. lab. If you make goods in China, ask the lab to run federal CPSIA tests and the Pennsylvania filling tests in one project. Expect to pay for the extra testing and for any re-tests that align reports with state forms. Plan to pay about $650 to $1,100 per SKU for this combined testing.
Practical Launch Checklist
- Confirm CPSIA and ASTM F963 first
- Draft one law label layout that satisfies PA, OH, and MA
- Order labels after the registration numbers are issued
- Run PA filling tests and keep reports by SKU
- Add three weeks to the launch timeline and tell your retailers
FAQs
Is this a new law in Pennsylvania?
Yes, the application requirement for flammability and tolerance reports began August 27, 2024.
Can I sell elsewhere while I wait?
Yes, you can sell outside PA, OH, and MA. Do not ship into those states until approval and labels are in place.
Do China test reports work?
Sometimes. If they are in English and from an acceptable lab. Many brands ask their China lab to run both federal and Pennsylvania tests in the same project. However, these states sometimes will ask you to re-test the products in the US in order to obtain the proper certifications.
How much time should I budget?
Plan 3 weeks for first filings, label printing, and report coordination.
