16 CFR § 1700.20, explained.

the rule, in one sentence

16 CFR § 1700.20 is the US Consumer Product Safety Commission's child-resistant packaging standard. It defines a test protocol: a package is "child-resistant" if, in a panel of 50 children aged 42-51 months, at least 85% cannot open it within 10 minutes using only their hands and teeth (rounds 1 and 2 of the test).

That's it. The whole rule is a behavioral test. Materials don't matter. Closure type doesn't matter. What matters is whether real kids, in a real lab, can actually open the package.

the second half of the test

The other half of CR certification is senior accessibility. The same package has to be openable by adults 50-70 years old — at least 90% of a 100-person senior panel must be able to open and re-close the package within 5 minutes.

Pop-top tubes pass both halves because the cap requires a downward push before the squeeze release — a coordination step kids under 5 generally can't do, but adults figure out in 5-10 seconds.

where ASTM D3475 fits in

ASTM D3475 is a parallel standard — a classification system for child-resistant packaging types. It overlaps almost entirely with 16 CFR § 1700.20 on the testing requirements. When a supplier says "ASTM D3475 compliant," they're effectively making the same claim as "CR-certified per 16 CFR § 1700.20."

State cannabis regulators in California (BCC/DCC), Colorado (MED), Oregon (OLCC), and most others reference one or both. Some states list specific cert numbers; most accept either.

what to actually request from your supplier

If a supplier says their tube is CR-certified, the documents that should arrive in your inbox within 24 hours:

1. The CR test report PDF. Multi-page document on third-party lab letterhead (Eurofins, Intertek, SGS, or similar). Should list test date, sample size (50 kids + 100 seniors), pass/fail rates, and the specific product tested by SKU.
2. The resin Certificate of Conformity. Polypropylene supplier's letter confirming FDA 21 CFR 177.1520 food-contact compliance for the resin grade used.
3. Country-of-origin documentation. Honest country listing for FTC labeling rules. "Made in USA" claims on Chinese-manufactured tubes are a fineable FTC offense.
4. Prop 65 declaration (if selling into California). Signed statement either declaring non-applicability or providing required warning text.

red flags to walk away from

"The factory has the cert, we'll request it for you" — this means they don't have it. A real supplier already has the PDF saved and forwards it within hours.

Other warning signs:

• "CR-equivalent" or "CR-style" — these phrases are not legal claims. The product either passed 16 CFR § 1700.20 testing or it didn't.
• No third-party lab letterhead on the PDF — internal factory reports don't count for regulatory acceptance. CR testing must be done by an accredited independent lab.
• The test report doesn't match the product SKU — sometimes suppliers send a cert for a similar-but-different mold or a different cap type. Match the report's SKU to your purchase order exactly.
• The cert is more than 3 years old without re-validation — CR certs don't formally "expire," but most cannabis regulators want recent validation, especially after any closure-mechanism change.

what we send, on request

Every Pack Guys wholesale account gets the full compliance pack on file before first shipment:

• 16 CFR § 1700.20 test report (third-party lab, our 116mm tube SKU)
• ASTM D3475 classification documentation
• Resin CoC (FDA 21 CFR 177.1520, BPA/phthalate-free)
• HTS classification: 3923.50.0000 (plastic stoppers/lids/closures)
• Country-of-origin documentation
• Prop 65 non-applicability declaration

You can also read our public CR cert summary right now — full PDFs go to verified wholesale accounts.