Choking Hazard Warnings on Amazon Toy Listings: 16 CFR 1500.19 and 1500.20

The warning on the back of a toy box is the part of toy compliance most sellers already know. What catches them is that the same statement, in the same words, has to appear on the Amazon listing itself, and that Amazon has a dedicated attribute for it that its systems check. Leave it out, shorten it, or contradict it with the age in your bullets, and the listing has a problem before a single unit ships.

This guide covers which toys need which cautionary statement, where the requirement to put it on the listing comes from, where Amazon expects it, and the age-grade mistakes that turn a correct warning into a violation.

The listing is an advertisement under 16 CFR 1500.20

The wording of the choking-hazard warnings comes from 16 CFR 1500.19, which covers toys and games intended for children from 3 to under 6 that contain small parts, plus balloons, small balls and marbles. That section puts the statement on the package.

16 CFR 1500.20 is the part sellers miss. Implementing section 24(c) of the Federal Hazardous Substances Act (15 USC 1278(c)), it requires the same cautionary statement in any advertisement that provides a direct means to purchase the product. An Amazon detail page with a buy button is the clearest possible example, and the rule has applied to internet listings since 2008-12-12. CPSC's small parts business guidance walks through the product scope.

So the question is not whether your box is right. It is whether the page says what the box says.

The four statements and when each applies

Each hazard has its own prescribed text. The forms below are as 16 CFR 1500.19(b) sets them out (the CFR renders them as images, so check the eCFR page for the layout and the safety-alert symbol):

• Small parts, for toys and games intended for ages 3 to under 6 that contain small parts: "WARNING: CHOKING HAZARD—Small parts. Not for children under 3 yrs."
• Small balls: "WARNING: CHOKING HAZARD—This toy is a small ball. Not for children under 3 yrs." or, where the ball is a component, "Toy contains a small ball."
• Marbles: "WARNING: CHOKING HAZARD—This toy is a marble. Not for children under 3 yrs." or "Toy contains a marble."
• Balloons, for latex balloons and toys containing them: "WARNING: CHOKING HAZARD—Children under 8 yrs. can choke or suffocate on uninflated or broken balloons. Adult supervision required. Keep uninflated balloons from children. Discard broken balloons at once."

A product can need more than one. A party pack with balloons and a bag of small favors carries both statements, and Amazon's attribute accepts up to four values for that reason.

Note what is not on the list: toys for children under 3. Under 16 CFR 1501, a product intended for under-3s may not contain small parts at all. The warning exists for the 3-to-under-6 band, where small parts are permitted but must be flagged. Keep that in mind for the age section below.

Where Amazon puts it: the cpsia_cautionary_statement attribute

Amazon does not read your bullets to find the warning. The Toys & Games listing template carries three fields that do the job:

• cpsia_cautionary_statement: one to four values drawn from the 16 CFR 1500.19 set, or the value for no warning applicable. Amazon renders this on the product page, which is where the 16 CFR 1500.20 listing warning lives.
• safety_warning: free text for any additional caution.
• manufacturer_minimum_age, with a unit in months or years, alongside age_range_description.

Toys & Games listings without the cautionary statement attribute are held. That includes listings for toys with no hazard, because an empty field is not the same as "no warning applicable". Choose the no-warning value on purpose.

Carry the statement in both places: set the attribute, and put the verbatim sentence in a bullet or the description. Amazon's attribute is what the page displays; the copy is what a seller, a reviewer or a scan reads. A warning that lives only inside a packaging photo depends on someone running OCR on it.

Check the field names against your own category template. Amazon's Seller Central help carries the Toys & Games requirements behind a login, and attribute names have shifted between flat-file versions.

Exact wording, or it does not count

16 CFR 1500.19(b) and (d) prescribe the words, the signal word WARNING and the safety-alert symbol. The statement is not a suggestion to be adapted to your brand voice. The alterations that show up most on Amazon listings:

What the listing says	Why it fails	What it should say
"Caution: small pieces, keep away from young kids"	Paraphrase, wrong signal word, no age	"WARNING: CHOKING HAZARD—Small parts. Not for children under 3 yrs."
"Choking hazard! Not suitable for babies"	Age limit replaced with a vague term	Same as above
"Not for children under 2"	Age changed	"Not for children under 3 yrs."
"Small parts, choking hazard" in a bullet with no signal word	Missing WARNING	The full statement
Balloon pack carrying only the small-parts statement	Wrong hazard	The balloon statement, children under 8 yrs.

Case, punctuation and line breaks are forgiving: a hyphen in place of the dash, or a line break on the label, does not change the statement. The words and the age do.

The age grade decides everything

Every rule above turns on the age grade, which is why the age-related failures are the most common and the most serious.

No age stated at all. ASTM F963-23 section 5, incorporated by 16 CFR 1250, requires age labeling on toys, and CPSC's Age Determination Guidelines (January 2020) are the reference for setting it. A listing with no minimum age anywhere, in the copy or in manufacturer_minimum_age, leaves Amazon and the shopper nothing to anchor the warning to. The age should come from the age-determination assessment behind your Children's Product Certificate, not from the marketing team. See what a CPC must contain.

Ages that disagree. The title says "perfect first toy for babies and toddlers", the attribute says 36 months, and the bullet says "Not for children under 3 yrs." Those three statements cannot all be true. A product marketed to under-3s that carries the under-3 warning is misbranded: either it has small parts and should not be sold to toddlers, or it does not and the warning is wrong. The same goes for an "Ages 8+" headline over an 18-month attribute, or an under-3 warning on something sold as a teether or rattle.

Product words are not age grades. "Stacking", "sorter" and "plush" describe products, not ages. A stacking toy marked ages 3+ is a 3+ toy; the word stacking does not make it a toddler product. Grade on the stated age and the assessment, then make every surface agree.

A pre-publish checklist

1. Take the age grade from the age-determination assessment, and state it in the copy and in manufacturer_minimum_age.
2. If the toy is for 3 to under 6 and contains small parts, a small ball, a marble or a balloon, choose the matching 16 CFR 1500.19(b) statement. More than one hazard means more than one statement.
3. Set cpsia_cautionary_statement, up to four values, or the no-warning value if none applies.
4. Paste the statement verbatim into a bullet or the description. No paraphrase, no shortened age.
5. Read every age mention across title, bullets, description, A+ content, images and attributes. They must agree with each other and with the warning.
6. Compare the packaging warning block image with the listing. The box and the page should match word for word.

Do this for every child ASIN in a variation family, because warnings and ages are often set once on the parent and never checked on the children.

Checking this across a catalogue

The rules are short; the work is in the volume. Each toy listing has a title, five bullets, a description, A+ modules, image text and a dozen attributes, and the age or the warning can drift in any of them. Verid8 scans toy listings against the CPSC requirements on our Toys, Games & Baby page, flags a missing or altered cautionary statement and any age contradiction with the exact text, and suggests the prescribed statement as the fix. It is the same check described here, run across every ASIN at once. For the claims side of toy copy, see safety claims that need proof.