Pet product testing confuses importers more than almost anything else in this trade, largely because the two major standards look interchangeable and are not. This guide explains how the testing actually works, what it costs, and how to sequence it so it does not become the expensive surprise at the end of an order.
First: which products need testing at all
Not every pet product is a regulated consumer product. The distinction that matters is whether the product is legally a toy.
- Toys — anything marketed for children, and in most jurisdictions anything a child could reasonably use as a toy — fall under toy safety legislation. This is the strictest category and the most expensive to test.
- General consumer products — bowls, leads, beds, carriers and grooming tools are not toys. They fall under general product safety and chemical restriction frameworks, which usually means a documented risk assessment, a declaration of conformity where a harmonised standard applies, and chemical testing where specific substances are relevant.
- Electrical products — clippers, heaters, water fountains, aquarium equipment. These carry their own conformity and safety marking requirements on top of general product safety.
- Food — treats and pet food. A completely separate regime with its own approvals and timelines.
Getting this classification right at the specification stage is the highest-leverage thing you can do, because it determines the entire compliance cost of the order.
EN71 and ASTM F963: different standards
EN 71 is the European standard series for toy safety. ASTM F963 is the US standard for toy safety. They overlap in intent and diverge substantially in method and limit.
| Aspect | EN 71 | ASTM F963 |
|---|---|---|
| Scope | EU market, several parts | US market |
| Mechanical properties | EN 71-1 | Equivalent section, different limits and methods |
| Flammability | EN 71-2 | Comparable but separately specified |
| Migration of elements | EN 71-3 | Comparable, different limits |
| Additional | Part 5, 6, 7 etc. depending on product | Phthalate and lead limits under CPSIA |
The practical consequences: a toy that passes EN 71 does not automatically pass ASTM F963, and a toy that fails ASTM F963 has not necessarily failed EN 71. Testing for both markets means two reports. If you sell into both, the efficient route is one laboratory accredited for both, running one programme.
CPSIA: the third-party testing requirement
The US framework adds requirements the EU does not have in the same form. Testing must be performed by a laboratory accepted by the Consumer Product Safety Commission. The importer must issue a Children’s Product Certificate. Tracking labels are required, and lead content and phthalate limits apply.
Two practical notes. The tracking label requirement means every unit needs a label with the manufacturer, location, date and batch — which is a packaging decision, not a testing one, and it needs to be planned before printing. And the Children’s Product Certificate is issued by the importer, based on the laboratory’s report, which means the report has to be in your hands before you can ship lawfully.
How the laboratory process actually works
- Define the test programme. Which standards, which parts, how many samples, which materials. This is the step that determines cost, and it is the step most often done badly.
- Sample selection. The laboratory needs samples representative of production. This is why pre-production samples are often tested and then production batches are verified against them.
- Testing. Weeks rather than days for a full toy programme. Testing times are quoted by the laboratory and are worth having in the delivery schedule.
- Report. A laboratory report identifying the product, the standard, the results and the sample. This is the document you keep and the document the market surveillance authorities will ask for.
- Technical file. For products requiring CE marking, the importer must be able to demonstrate technical documentation exists and is retained.
Batch testing versus pre-production testing
This is the distinction that protects importers from the worst outcome. Testing production samples confirms the goods in your container comply. Testing pre-production samples confirms that the specification was achievable. Both have a place, and they are not interchangeable.
Where the standard requires testing of the production batch — and for toys it generally does — a report on pre-production samples is not a substitute for a report on the batch that shipped. Getting this wrong means a container arrives with no valid evidence of conformity.
What testing costs, and how to control it
Testing is usually a fixed cost per order rather than per unit, which changes the economics of consolidation. One programme covering several product types from one order costs far less than three separate programmes from three separate orders.
The ways importers waste money:
- Testing the same materials separately for different products. If two products share a material, the material results are usually reusable. Grouping products by material before commissioning tests reduces cost.
- Testing before the specification is settled. A changed material means a new test. Settle the specification, then test.
- Testing to both markets when you only need one. Confirm your destination before commissioning.
- Not asking the laboratory for a quote alongside the factory quote. Then the testing cost appears late and unplanned.
Sequencing it so it is not a surprise
The order that avoids the expensive surprise is: confirm destination market, confirm the product classification, confirm the applicable standards and the acceptable documentation form, commission the test alongside the factory order, allow the testing timeline in the delivery schedule, and confirm labelling against the specific market before printing.
The compliance page sets out the market-by-market requirements in detail.
Frequently asked questions
Do I need testing if my product is only sold online?
Yes. Distance selling does not exempt a product from the requirements that apply to it. In fact most markets now require specific information to be displayed in distance-selling listings, which is an additional obligation on top of the product requirements themselves.
Can one report cover several products?
Sometimes, when products share materials and the laboratory issues a report covering a family of products. It depends on the laboratory and the standard, and it needs to be agreed before the programme starts rather than requested afterwards.
How long does testing take?
Typically two to four weeks for a full toy programme, plus laboratory queue time. Add the sample production and shipping time on top. This is why it needs to be inside the delivery schedule from the beginning.
What if the test fails?
Then it happened before the container was loaded, which is the good outcome. Depending on the failure, the options are a material substitution with retesting, a design change, or rework. This is exactly why the specification and sample stage matters — a failure caught on a sample costs a sample, while a failure caught on finished goods costs a container.
Does a supplier’s certificate count?
It depends what the certificate is. A laboratory report from an accredited body has a defined evidential meaning. A supplier’s own statement of compliance has a much weaker position, and in an enforcement action it may not be sufficient. Ask for the document, not the assurance.
Who is responsible for holding the technical file?
The importer placing the goods on the market. You cannot rely on the factory to hold it on your behalf, and the requirement to retain it for a defined period after the goods reach the market is one that is easy to forget once the shipment is delivered.