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Third-party product inspection, explained
Product Inspection

Children's Product Certificate (CPC): who issues it, what testing it rests on, what it lists

Sources checked

Children's products that are subject to a consumer product safety rule require third-party testing and certification. The domestic manufacturer or importer certifies in a written Children's Product Certificate (CPC) based on test results from a third-party, CPSC-accepted laboratory — Section 14 of the CPSA, as codified in 16 CFR part 1110, as described on CPSC's Children's Product Certificate page. For what the certificate must contain, current 16 CFR 1110.11 governs.

What counts as a children's product

CPSC's Children's Products page gives the statutory definition: the law defines a "children's product" as a consumer product designed or intended primarily for children 12 years of age or younger. That page states that children's products are required to undergo third-party testing and to have a written CPC demonstrating compliance.

The same page describes a separate certificate for a different group. "Certain general use products subject to mandatory consumer product safety rules are required to undergo testing or be subjected to a reasonable testing program and have a written General Certificate of Conformity (GCC) demonstrating compliance."

Who issues the certificate

Current 16 CFR 1110.7 addresses this in two subsections, each with its own opening condition.

For products manufactured outside the United States, § 1110.7(a) reads: "Except as otherwise provided in a specific rule, ban, standard, or regulation enforced by CPSC, for a finished product manufactured outside of the United States that must be accompanied by a certificate as set forth in § 1110.5, the importer, as defined in this part, is the finished product certifier that must issue a finished product certificate that meets the requirements of this part."

For products manufactured in the United States, § 1110.7(b) reads: "Except as otherwise provided in a specific rule, ban, standard, or regulation enforced by the Commission, for a finished product manufactured in the United States that must be accompanied by a certificate, as set forth in § 1110.5, the manufacturer is the finished product certifier that must issue a finished product certificate that meets the requirements of this part. However, if a finished product manufactured in the United States is privately labeled, the private labeler is the finished product certifier that must issue a finished product certificate that meets the requirements of this part, unless the manufacturer issues the finished product certificate."

What testing the certificate rests on

CPSC's Third Party Testing Guidance page states that federal law requires that every children's product be tested by a third-party, CPSC-accepted laboratory for compliance with the applicable federal children's product safety requirements. CPSC's Testing & Certification page puts the same duty on the party itself: "A manufacturer or importer of a children's product must use a third party, CPSC-accepted laboratory to test its product for compliance with the applicable federal children's product safety requirements."

The same guidance page sets out several conditions that shape how testing is carried out:

  • CPSC has accepted more than 600 laboratories worldwide to perform testing for a variety of requirements for children's products.
  • Because accreditation is rule-specific, not all laboratories can conduct all applicable testing; firms may be required to use more than one laboratory to perform all of the required testing for a particular product.
  • The specifics of conditions and requirements for component part testing (which includes composite testing) are codified at 16 CFR part 1109.
  • If material changes are made to a children's product after initial certification, the finished product or the component part that was changed must be retested for compliance with those rules affected by the material change.
  • 16 CFR § 1107.21 requires periodic testing for children's products that are in continuous manufacture.

CPSC's Rules Requiring Third-Party Testing page says its list "is complete as of December 5, 2024," and that an up-to-date list for rules requiring third-party testing is codified at 16 CFR § 1112.15. On small batch manufacturers, the same page says: "Qualifying and registered small batch manufacturers (SBM) may be able to receive relief from third party testing to certain safety rules (Group B requirements); registered SBMs may certify to Group B requirements via means other than testing by third-party, CPSC-accepted laboratories." Its ASTM F963 footnote reads: "The CPC must also include the individual sections of the currently accepted version of ASTM F963 applicable to the product and not simply cite 16 CFR part 1250."

What the CPC page lists

CPSC's Children's Product Certificate page sets out seven required elements:

  1. Identification of the product covered by this certificate
  2. Citation to each CPSC children's product safety rule to which this product is being certified
  3. Identification of the domestic manufacturer or importer certifying compliance of the product
  4. Contact information for the individual maintaining records of test results
  5. Date and place of manufacture
  6. Date(s) and place(s) of testing
  7. Identification of any third-party, CPSC-accepted laboratory who conducted the testing

The same page adds three format notes. "No specific template or format need be followed when generating a certificate as long as the 7 required elements (see below) are present and accurate." "The CPC and supporting test reports must be in English." And on the date of manufacture: "For the date(s) of manufacture, provide at least the month and year (or starting month and year for a continuous batch)."

That page also carries its own status note: it may not yet reflect the eFiling requirements that begin on July 8, 2026.

What 16 CFR 1110.11 requires

Current 16 CFR 1110.11(a) lists seven items, which are worded differently from the guidance page's list. Each finished product certificate must:

  1. Identify the finished product(s) covered by the certificate. The certificate must contain at least one of the following unique identifiers: global trade item number (GTIN), model number, registered number, serial number, stock keeping number (SKU), universal product code (UPC), or alternate identifier, along with a sufficient description to match the finished product to the certificate. It may also include other identifiers, such as lot number, model style, and model color.
  2. State each rule the product is certified to. The certificate must state each consumer product safety rule under the CPSA, or similar rule, ban, standard, or regulation under any law enforced by the Commission, and must identify separately all applicable rules, bans, standards, or regulations.
  3. Identify the finished product certifier, as set forth in § 1110.7, including the party's name, street address, city, state or province, country or administrative region, electronic mail (email) address, and telephone number.
  4. Identify the individual maintaining records listed in § 1110.17 on behalf of the certifier, with contact information consisting, at a minimum, of the individual's name, street address, city, state or province, country or administrative region, email address, and telephone number. The individual can be a position title, provided that the position is always staffed and responsive to CPSC's requests.
  5. Provide the date and place of manufacture, with month and year at a minimum, and the place including a manufacturer name, street address, city, state or province, country or administrative region, email address, and telephone number. For manufacturing runs over a series of days, provide the initial date of manufacture (month and year, at a minimum).
  6. Provide the most recent date and place(s) of testing, including, for each third party conformity assessment body or other party on whose testing the certificate depends, the name, street address, city, state or province, country or administrative region, email address, and telephone number.
  7. Provide the finished product certifier's attestation. For eFiled certificates required in § 1110.13(a)(1), attestations are included in the Product Registry and in CPSC's PGA Message Set CATAIR Implementation Guide (including revisions thereto). Paper and electronic finished product certificates described in § 1110.9(b) and (c), and required in §§ 1110.13(a)(2), (b), and (c), must include the attestation by the finished product certifier: "I hereby certify that the finished product(s) covered by this certificate comply with the rules, bans, standards, and regulations stated herein, and that the information in this certificate is true and accurate to the best of my knowledge, information, and belief. I understand and acknowledge that it is a United States federal crime to knowingly and willfully make any materially false, fictitious, or fraudulent statement, representation, or omission on this certificate."

Three further subsections sit alongside that list:

  • § 1110.11(b), electronic access to records. In addition to identifying the individual maintaining records, a certificate may include a URL, or other electronic means, providing electronic access to the required underlying records to support the certificate.
  • § 1110.11(c), statutory or regulatory testing exclusions. Unless otherwise provided by the Commission, if a certifier claims a statutory or regulatory testing exclusion, the certificate identifies the applicable testing exclusion, in addition to listing all applicable rules, bans, standards, and regulations, and in lieu of providing the date and place where testing was conducted for that regulation under § 1110.11(a)(6).
  • § 1110.11(d), duplicative testing not required. Although certificates must list each applicable rule, ban, standard, or regulation separately, certifiers are not required to conduct the same third party test on each sample more than once when a rule references, or incorporates fully, another applicable rule with the same requirement.

CPSC's Children's Product Certificate page adds a related point about untested products: "Where a product is subject to exemptions or exceptions within a regulation, manufacturers and importers must still create and issue a CPC, citing all applicable regulations, and listing the exception or exemption claimed, instead of listing a third-party laboratory, for those products that were not tested."

Language, format and where the certificate goes

Current 16 CFR 1110.9(a) covers language: an eFiled finished product certificate must be in the English language, and "All other certificates, including hard copy and electronic certificates, must be in the English language and may also contain the same content in any other language." Subsection (b) covers format, including the electronic certificate conditions described in § 1110.9(c).

Availability runs through § 1110.13:

  • § 1110.13(a) — a finished product certificate must accompany each finished product or finished product shipment required to be certified, and each certificate must describe only one product.
  • § 1110.13(a)(1) — for products manufactured outside the United States and offered for importation, the certifier must eFile the certificate data elements required in § 1110.11 at the time of filing the entry in ACE; for products imported by mail, the certifier must enter those data elements into CPSC's Product Registry before arrival of the product or substance in the United States. eFiling has its own coverage elsewhere.
  • § 1110.13(b) — a certifier must furnish the required certificate to each distributor or retailer of the finished product.
  • § 1110.13(c) — certifiers must make finished product certificates available for inspection immediately, "meaning within 24 hours, upon request by CPSC or CBP."

CPSC's Testing & Certification page describes the same arrangement in plain terms: "Certificates are required to accompany the applicable product or shipment of products covered by the certificate, and a copy must be provided to retailers, distributors and, upon request, to the government."

What a certifier stays responsible for

Current 16 CFR 1110.15 states its points in this order. Finished product certifiers may, directly or through another entity, maintain an electronic certificate platform. Pursuant to part 1109 of this chapter, a finished product certifier may rely on another party to test or certify component parts or finished products. Also, for purposes of § 1110.13(a)(1), a finished product certifier may rely on another party to enter data into the Product Registry or to certify finished products on their behalf. The finished product certifier, identified in § 1110.7, remains legally responsible for the information in a finished product certificate, including its validity, accuracy, completeness, and availability.

An example certificate

CPSC's CPC Example – Toy page carries a disclaimer: "The following is a fictitious example of a CPC for a children's toy." The same page notes that "For products intended for children under 3 years of age, the appropriate citation for the small parts requirement is 16 CFR Part 1501."

Questions people ask

Who issues a Children's Product Certificate?

For a finished product manufactured outside the United States, § 1110.7(a) makes the importer the finished product certifier. For a finished product manufactured in the United States, § 1110.7(b) makes the manufacturer the certifier, and makes the private labeler the certifier if the product is privately labeled, unless the manufacturer issues the certificate. Both subsections begin with "Except as otherwise provided in a specific rule, ban, standard, or regulation."

Which laboratory does the testing?

CPSC's Testing & Certification page says a manufacturer or importer of a children's product must use a third party, CPSC-accepted laboratory. CPSC's Third Party Testing Guidance page notes that accreditation is rule-specific, so firms may be required to use more than one laboratory to perform all of the required testing for a particular product.

Does a CPC need a template?

CPSC's Children's Product Certificate page states that "No specific template or format need be followed when generating a certificate as long as the 7 required elements (see below) are present and accurate."

What happens after a material change to a certified children's product?

CPSC's Third Party Testing Guidance page states that if material changes are made after initial certification, the finished product or the component part that was changed must be retested for compliance with those rules affected by the material change.

Do all children's products need periodic testing?

CPSC's Third Party Testing Guidance page cites 16 CFR § 1107.21, which requires periodic testing for children's products that are in continuous manufacture.

Must the certificate be in English?

CPSC's Children's Product Certificate page says "The CPC and supporting test reports must be in English." Current 16 CFR 1110.9(a) adds that other certificates "may also contain the same content in any other language."

What happens for products that were not tested?

CPSC's Children's Product Certificate page states that where a product is subject to exemptions or exceptions within a regulation, manufacturers and importers must still create and issue a CPC, listing the exception or exemption claimed instead of listing a third-party laboratory.

How quickly must a certifier make a certificate available to CPSC or CBP?

Current 16 CFR 1110.13(c) says finished product certifiers must make finished product certificates available for inspection immediately, meaning within 24 hours, upon request by CPSC or CBP.

Sources

Checked 11 October 2026.

This page is an unofficial summary and is not affiliated with the U.S. Consumer Product Safety Commission or U.S. Customs and Border Protection; the official text governs.

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