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CPSC citation code 1278a: Total Lead Content for Children's Products

Code 1278a is the eFiling citation code CPSC assigns to 15 USC 1278a (Total Lead Content for Children's Products). You enter it exactly as shown when you certify a product to this rule, whether in the CPSC Product Registry, in a Product Registry bulk-upload CSV, or in a Full PGA Message Set filed by your customs broker.

Citation code	`1278a`
Regulation	15 USC 1278a: Total Lead Content for Children's Products (official text)
Certificate type(s) in CPSC's list	CPC (children's products)
Testing exclusions linked to this code	21

Testing and certification

On a CPC (children's products): certification must be based on testing by a CPSC-accepted third-party laboratory; in the Registry CSV that lab is entered as Lab Type ITL with its CPSC lab ID.

Whichever certificate you issue must contain all seven elements of 16 CFR 1110.11: product ID, each applicable rule (including this one), certifier, records custodian, date and place of manufacture, date and place of testing, and the attestation. See CPC guidance / GCC guidance.

Testing exclusions you can claim with 1278a

If an exclusion applies, still cite 1278a, and add the exclusion code under a lab entry with Type NOL (no lab) instead of a test date and lab (CPSC citation/exclusion guidance, Sept 2026).

Exclusion code	What CPSC excludes
`1252.3(a)(1)`	16 CFR 1252.3(a)(1): Determinations regarding lead for particleboard that is untreated and unfinished made from virgin wood or pre-consumer wood waste
`1252.3(a)(2)`	16 CFR 1252.3(a)(2): Determinations regarding lead for hardwood plywood that is untreated and unfinished made from virgin wood or pre-consumer wood waste
`1252.3(a)(3)`	16 CFR 1252.3(a)(3): Determinations regarding lead for medium-density fiberboard that is untreated and unfinished made from virgin wood or pre-consumer wood waste.
`1500.88(d)(1)`	16 CFR 1500.88(d)(2): Exemption from lead limit under 15 USC 1278a for lead blended into the glass of cathod ray tubes, eletronic components, and fluorescent tubes in electronic devices
`1500.88(d)(5)`	16 CFR 1500.88(d)(5): Exemption from lead limit under 15 USC 1278a for lead used in lead-bronze bearing shells and bushings in electronic devices
`1500.88(d)(6)`	16 CFR 1500.88(d)(6): Exemption from lead limit under 15 USC 1278a for lead used in compliant pin connector systems in electronic devices
`1500.88(d)(7)`	16 CFR 1500.88(d)(7): Exemption from lead limit under 15 USC 1278a for lead used in optical and filter glass in electronic devices
`1500.88(d)(8)`	16 CFR 1500.88(d)(5): Exemption from lead limit under 15 USC 1278a for lead oxide in plasma display panels and surface conduction electron emitter displays in electronic devices
`1500.88(d)(9)`	16 CFR 1500.88(d)(5): Exemption from lead limit under 15 USC 1278a for lead oxide in the glass envelope of black light blue lamps in electronic devices
`1500.91(d)(1)`	16 CFR 1500.91(d)(1): Determination regarding lead content for precious gemstones
`1500.91(d)(2)`	16 CFR 1500.91(d)(2): Determination regarding lead content for semiprecious gemstones and other minerals
`1500.91(d)(3)`	16 CFR 1500.91(d)(3): Determination regarding lead content for natural or cultured pearls
`1500.91(d)(4)`	16 CFR 1500.91(d)(4): Determination regarding lead content for wood
`1500.91(d)(5)`	16 CFR 1500.91(d)(5): Determination regarding lead content for paper and similar materials made from wood or other cellulosic fiber
`1500.91(d)(6)`	16 CFR 1500.91(d)(6): Determination regarding lead content for CMYK process printing inks
`1500.91(d)(7)`	16 CFR 1500.91(d)(7): Determination regarding lead content for textiles
`1500.91(d)(8)`	16 CFR 1500.91(d)(8): Determination regarding lead content for other plant-derived and animal-derived materials
`1500.91(e)(1)`	16 CFR 1500.91(e)(1): Determination regarding lead content for certain surgical steel and stainless steel
`1500.91(e)(2)`	16 CFR 1500.91(e)(2): Determination regarding lead content for certain precious metals
`1278a(b)(5)`	15 USC 1278a(b)(5): Exemption from lead limit for off-highway vehicles
`1278a(b)(7)`	15 USC 1278a(b)(7): Exemption from lead limit for used children's products

How to enter code 1278a

Product Registry CSV (CSV Guide V3): put it in the Lab N Citation Codes column of the lab that tested it; separate several codes with a semicolon, e.g. 1278a; 1303. Do not add commas.
Product Registry web form: pick 1278a from the citation drop-down.
Full PGA Message Set: your broker sends it in a PG60 record (one PG60 per citation).

HTS categories where this rule is common

Based on CPSC's product categories in its Oct 2026 HTS flag list; confirm against your own product:

Wearing Apparel (403 flagged HTS codes)
Child Chairs (37 flagged HTS codes)
Toys (13 flagged HTS codes)
Imitation Jewelry (11 flagged HTS codes)
Children's Shoes (9 flagged HTS codes)

Deadlines

July 8, 2026: eFiling mandatory for imported regulated products (formal and informal entries); new certificate content rules (16 CFR 1110.11) apply to domestic and imported products.
January 8, 2027: products entered for consumption or warehousing from a Foreign Trade Zone.
January 20, 2027: international mail shipments filed under CBP's new Entry Type 13.
There is no de minimis exemption for eFiling. Sources: Final Rule (90 FR 1800), CPSC mail guidance (Oct 2026).

These are the most common citations on Children's Product Certificates. Total lead content (15 U.S.C. 1278a) applies to accessible parts of children's products, the lead paint ban (16 CFR 1303) to paint and similar surface coatings, and the phthalates prohibition (16 CFR 1307) to children's toys and child care articles. CPSC has issued material determinations (e.g. 16 CFR 1500.91, 1252, 1253, 1308) that let certifiers claim a testing exclusion instead of testing certain untreated materials.

1303 · 1307

Free tools: Check whether your product needs a CPC/GCC and eFiling · Validate your Product Registry CSV · Generate a certificate + Registry CSV

Source: CPSC eFiling Citation and Testing Exclusion Codes (Dec 18, 2025).