Two federal standards govern child-resistant packaging in the United States. Most brands know they exist. Far fewer understand what each one actually covers, how they differ in testing protocol, which one their state requires, and what happens when the standard on the documentation doesn’t match the standard the regulator is asking for.

This is the definitive guide to both standards — what they are, how they work, where they apply, and how to make sure your CR packaging documentation is aligned with the right one for your specific product and market.

Why Two Standards Exist

Child-resistant packaging requirements in the US originate from the federal Poison Prevention Packaging Act (PPPA) of 1970, administered by the Consumer Product Safety Commission (CPSC). The PPPA established the authority to require CR packaging for household substances that pose a risk to children — initially pharmaceuticals, then extending to other product categories including cannabis as state-level regulation developed.

The CPSC created 16 CFR §1700.20 as the federal testing protocol under the PPPA. ASTM International — an independent standards organization — subsequently developed its own standard for reclosable packaging that aligns with but is not identical to the CPSC protocol. The two standards exist in parallel, with different scopes and different industry adoption patterns.

Understanding both matters because state cannabis regulations reference them differently, and a package certified to one may or may not satisfy a requirement referencing the other.

ASTM Standard for Reclosable Packaging

What It Covers

The ASTM standard applies specifically to reclosable packaging — containers designed to be opened, used, and resealed multiple times. This is the standard most directly applicable to cannabis tins, glass jars, and other multi-use containers where the CR mechanism is a reclosable closure.

The Testing Protocol

ASTM testing is conducted by an accredited independent laboratory using human subject panels.

The child panel uses children ages 42 to 51 months — a range selected because it represents the developmental window where fine motor skills are present but not yet sufficient to reliably execute the multi-step or directional actions that CR closures require. Test children are given the package without demonstration or instruction and observed attempting to open it for a 10-minute period. The package passes the child panel if at least 85% of test children cannot open it within the 10-minute window.

The adult panel uses participants ages 50 to 70 — the population most likely to experience reduced hand strength or dexterity. Participants receive the package with written instructions (no demonstration) and are given 5 minutes to open and close it. The package passes the adult panel if at least 90% of adults can successfully complete both the opening and reclosing within 5 minutes.

Both panels must pass. A package that 95% of children cannot open but that 40% of adults also cannot open fails ASTM certification.

Where ASTM Is Most Commonly Used

ASTM certification is the standard most commonly applied to reclosable cannabis packaging formats — tins, jars, and tubes — in states that accept either standard. Some states with licensed cannabis programs accept ASTM certification for reclosable formats as equivalent to 16 CFR §1700.20 certification.

16 CFR §1700.20 — The CPSC Standard

What It Covers

16 CFR §1700.20 is the Consumer Product Safety Commission’s testing standard under the federal Poison Prevention Packaging Act. Unlike the ASTM standard, which is specifically written for reclosable packaging, 16 CFR §1700.20 applies to both reclosable and non-reclosable packaging formats. It is the broader standard and the one referenced by name in most state cannabis regulations.

The Testing Protocol

The 16 CFR §1700.20 protocol uses similar panel methodology to ASTM with specific procedural differences in how the test is administered.

The child panel uses the same 42–51 month age range and the same 10-minute observation window as ASTM. The pass threshold is the same: at least 85% of children must fail to open the package within the test period. The procedural differences in how the test is administered — how multiple child attempts are counted, how testing sessions are structured — can affect outcomes at the margins, which is why the standards are not fully interchangeable even when the stated thresholds are identical.

The adult panel uses the same 50–70 age range and 5-minute window. The pass threshold is again the same: at least 90% of adults must successfully open and close the package. Procedural differences in the adult panel protocol are the area where 16 CFR §1700.20 and ASTM diverge most significantly for practical purposes.

Non-reclosable formats — packaging that is not designed to be resealed after opening — are tested differently under 16 CFR §1700.20 than under ASTM, which does not cover this category. For single-use or one-time-open formats, 16 CFR §1700.20 is the applicable standard.

Where 16 CFR §1700.20 Is Required

Most state cannabis regulations require 16 CFR §1700.20 certification for retail cannabis products. California, New York, Michigan, Massachusetts, Illinois, Vermont, North Carolina, and most other licensed markets reference this standard specifically. It is the standard that cannabis compliance inspectors in these markets are looking for documentation of when they conduct packaging compliance reviews.

How the Two Standards Compare

Why the Distinction Matters in Practice

State Compliance

The most common compliance documentation gap in cannabis packaging is a brand whose packaging is certified to ASTM operating in a state that specifically requires 16 CFR §1700.20. The thresholds look identical. The format may be functionally the same. But the state inspector who asks for 16 CFR §1700.20 documentation and receives an ASTM test report has a documentation gap that constitutes a compliance issue.

Before entering any new state cannabis market, confirm specifically which standard that state’s regulations reference for your product category. Don’t assume that ASTM and 16 CFR §1700.20 are interchangeable in your market until you’ve confirmed it.

Multi-Format Brands

For brands with multiple CR packaging formats across their product line — tins for pre-rolls, jars for flower, bags for edibles — different formats may carry different certifications. A tin certified under ASTM and a bag certified under 16 CFR §1700.20 require separate documentation even though both are “CR certified.” Your packaging compliance register should track which standard applies to each active SKU.

Reorder Documentation

ASTM and 16 CFR §1700.20 certification applies to the specific package as tested, not to a general format. When a supplier reorders the same format from a different production run, the certification is only as current as the most recent confirmation that the production run matches the tested specification. A test report from 2022 covers the 2022 format — not necessarily what’s being produced today.

Request written confirmation at every reorder that the current production run matches the tested specification for the applicable standard. This is the documentation habit that keeps the compliance picture current regardless of which standard applies.

What “Certified” Actually Requires

Both ASTM and 16 CFR §1700.20 certification require:

Third-party laboratory testing. Neither standard can be self-certified by the packaging manufacturer, the supplier, or the brand. An accredited independent laboratory must conduct the panel testing and issue the test report.

Human subject panels. Certification is not a design review or a simulation. Real children in the specified age range and real adults in the specified age range must attempt to open the package under controlled conditions.

Documented pass rates. The test report must document the actual percentage of child panel participants who failed to open the package, and the actual percentage of adult panel participants who successfully opened and reclosed it. Pass rates that meet or exceed the thresholds (85% child, 90% adult) are required for certification.

Format specificity. The test report applies to the specific package and closure mechanism tested — not to a format category, a product line, or a supplier’s brand. Changes to the closure, material, dimensions, or manufacturing process may require retesting.

A supplier who says packaging is “certified” but cannot provide a third-party test report documenting these specifics has not formally certified the format regardless of how the product listing describes it.

TPC’s CR Certification Documentation

TPC’s CR packaging line carries 16 CFR §1700.20 certification across all formats — tins, tubes, jars, bags, and topical packaging. Third-party test documentation is available on request before any production commitment, covering the specific format and closure mechanism being ordered.

Written reorder confirmations — confirming that the current production run matches the tested specification — are standard at every order as part of TPC’s documentation process.

For brands building or maintaining a packaging compliance register, our audit-readiness guide covers how to structure documentation across multiple SKUs and maintain currency across reorders.

Browse TPC’s child-resistant packaging solutions or contact our team to request documentation for any format in our line.

Frequently Asked Questions

What is the difference between ASTM and 16 CFR §1700.20 for child-resistant packaging? Both are US federal testing standards for CR packaging with similar threshold requirements — 85% child panel failure rate and 90% adult panel success rate. ASTM applies specifically to reclosable packaging and uses ASTM International’s testing protocol. 16 CFR §1700.20 is the CPSC standard under the federal Poison Prevention Packaging Act and applies to both reclosable and non-reclosable packaging. Most state cannabis regulations require 16 CFR §1700.20 by name, though some states accept either standard for reclosable formats.

Can ASTM certification satisfy a state requirement for 16 CFR §1700.20? It depends on the state. Some states explicitly accept either standard for reclosable formats. Others specifically require 16 CFR §1700.20 and do not accept ASTM as a substitute. Confirm your specific state’s requirement before relying on ASTM certification in a market that may require 16 CFR §1700.20.

What does “CR certified” actually mean? It means the specific package and closure mechanism has passed third-party panel testing under ASTM or 16 CFR §1700.20, conducted by an accredited independent laboratory, with documented pass rates meeting the required thresholds. It does not mean the supplier assessed the design as child resistant, that the product listing says CR, or that a Certificate of Compliance exists without an underlying test report.

Does CR certification expire? Certification does not expire on a calendar schedule but can become invalid if the format changes. Any modification to the closure mechanism, material, dimensions, or manufacturing source after the original test may mean the existing certification no longer covers current production. The safeguard is a written reorder confirmation at each order that the current production matches the tested specification.

What is the child panel age range for CR certification testing? Both ASTM and 16 CFR §1700.20 use children ages 42 to 51 months (approximately 3.5 to 4.25 years). This range is specifically selected because it represents the developmental window where children have sufficient fine motor capability to attempt CR packaging but have not yet developed the coordination required to reliably execute multi-step or directional opening mechanisms.

Why do both ASTM and 16 CFR §1700.20 require adult panel testing? CR certification requires that packaging be difficult for children to open AND accessible for adults. A package that 100% of children cannot open but that 40% of adults also cannot open fails certification. The adult panel test — requiring 90% of adults ages 50–70 to open and close within 5 minutes — ensures that CR mechanisms don’t create barriers for the adult populations most likely to use them.