Child-Resistant Certification: 16 CFR 1700.20 & ASTM D3475.

Plain-English guide to what makes cannabis packaging legally child-resistant.

CR Certification

Overview

Child-Resistant Certification: 16 CFR 1700.20 & ASTM D3475

16 CFR 1700.20: The Testing Protocol

16 CFR 1700.20 is the federal standard that defines how child-resistant packaging is tested. It's administered by the Consumer Product Safety Commission. The test involves two groups. First, 50 children between 42 and 51 months old are given the package and instructed to open it. If at least 85% can't open it within 10 minutes, the first test passes. Then 100 adults between 50 and 70 years old must be able to open and properly close the package within 5 minutes. Both groups have to pass.

This test is not something a manufacturer can self-certify. It has to be run by a CPSC-accepted testing laboratory. The lab issues a report. That report is your proof. If a supplier says their packaging is CR but can't produce a lab report, the certification doesn't exist.

ASTM D3475: The Classification System

ASTM D3475 is a separate standard that classifies CR packaging into types based on the opening mechanism. Type I is a package requiring two simultaneous motions. Type II uses a single motion. Type III needs a key or tool. There are others. The classification matters because some state regulations reference a specific ASTM type. If your state says "Type I CR packaging required" and you bought Type II, you're not compliant.

When you request a quote from us, we tell you which ASTM type the packaging is certified under. We include the lab report with the order. That's not a courtesy. It's what a real factory-direct supplier does. Brokers often can't provide this because they don't know which factory made the product or which test applies.

What we offer

16 CFR 1700.20 explained
ASTM D3475 classification
CPSC / lab certification
Re-certification on design change
Reports on request

One honest, all-in price.

We work directly with a bench of factories - not as a broker. So we match you to the right one and bring back the best all-in price: packaging, printing, shipping, and any duties or tax - in one number with no middleman and no surprises.

Questions

Everything you need to know.

Who can perform 16 CFR 1700.20 testing?

Only laboratories accepted by the US Consumer Product Safety Commission. The CPSC maintains a public list of accepted testing facilities. If your supplier's test report comes from a lab not on that list, the certification is invalid. Ask for the lab name and verify it yourself on the CPSC website.

What happens if my packaging fails a compliance audit?

You could face fines, product recall, or loss of your license depending on your state. Most state regulators check CR certification during facility inspections. If you can't produce a valid lab report, they can pull your product from shelves. Keep your certification documents on file and accessible.

Is ASTM D3475 the same as 16 CFR 1700.20?

No. They're complementary. 16 CFR 1700.20 is the testing protocol that proves the package is child-resistant. ASTM D3475 classifies the package type based on how it opens. A package can pass 16 CFR 1700.20 and be classified as ASTM D3475 Type I. You may need both documents for compliance in your state.

Do CR certifications transfer between products?

No. The certification is specific to the exact closure mechanism, material, and dimensions tested. If a manufacturer changes the zipper, the lid, the plastic resin, or the size, the certification may no longer apply. A new test is required. That's why you need a report that matches your exact product.

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