You will also need to consider that the laws can be interpreted in different ways.  The powers that be may decide that the end factory is considered the “manufacturer” and will likely have sales well over one million per year, in which case the law requiring safety testing will now unexpectedly apply to you and your toys.  

I make toys for clients that ship to Walmart and Amazon.  These companies’ safety testing requirements have become even more strict as of late 2013 with updated rules and regulations, specifically with labeling.  This has not posed any problems for me as I follow strict standards with documentation, labeling, and follow many, many steps to make sure your product is ready for retail store shelves.

The only reason I have this information available is to educate people who are thinking about making their own toys. Whether you’re dealing directly with a factory (which I’d not recommend without years of experience) or using an agent, make sure you have an answer in writing that clearly answers these questions:

“Will my production run be safety tested to comply with CPSIA (or your country’s) safety regulations by a US Congress-approved safety testing lab? And will you provide a legally valid Children’s Product Certification?”

I hope this information has been helpful to you.