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Third-party product inspection, explained
Product Inspection

General Certificate of Conformity (GCC): which general-use products need one

Sources checked

A General Certificate of Conformity applies to certain general-use products, not children's products. CPSC's General Certificate of Conformity page puts it this way: "Except as otherwise stated in a specific standard, section 14(a) of the CPSA, as codified in 16 CFR part 1110, requires domestic manufacturers and importers of certain general-use products (i.e., non-children's products) that are subject to a consumer product safety rules, or a similar rule, ban, standard or regulation under any other CPSC-enforced statute, to certify, in a written General Certificate of Conformity (GCC) based on testing or a reasonable testing program (see 'What is a reasonable testing program?' on our GCC FAQs for more information), that their product(s) comply with applicable product safety rules."

Which products need a GCC

The scope on that page turns on two qualifiers kept in its wording: "certain" general-use products, and the exception "except as otherwise stated in a specific standard."

CPSC's Children's Products page describes the same group from the testing side: "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."

Testing and certification for children's products runs on a separate track. The General Certificate of Conformity page notes: "Note: Domestic manufacturers and importers of children's products are subject to different testing and certification requirements." CPSC's Children's Products page states that those products "are required to undergo third-party testing and to have a written Children's Product Certificate (CPC) demonstrating compliance," and defines a "children's product" as a consumer product designed or intended primarily for children 12 years of age or younger.

Which rules fall inside the GCC requirement is set out on a separate document linked from the page under the title "List of safety rules requiring a GCC."

The seven elements on the GCC page

The page lists seven elements a GCC has to carry, each with its own instruction.

  1. Identification of the product covered by this certificate — "Describe the product(s) covered by this certification in enough detail to match the certificate to each product it covers and no others."
  2. Citation to each CPSC product safety rule to which this product is being certified — "The certificate must identify each applicable safety rule (see link above). If an exemption applies that makes testing to a particular safety rule unnecessary, note the citation for the exemption under the safety rule (see GCC examples for recommendations on how to cite exemptions)."
  3. Identification of the domestic manufacturer or importer certifying compliance of the product — "Provide the name, full mailing address, and telephone number of the firm."
  4. Contact information for the individual maintaining records of test results — "Provide the name, full mailing address, e-mail address, and telephone number of the person maintaining test records in support of the certification. The person does not need to be from the firm identified in element 3, but it is the responsibility of the firm identified in element 3 to facilitate the provision of test reports when requested."
  5. Date and place of manufacture — "For the date(s) of manufacture, provide at least the month and year (or starting month and year for a continuous batch). For the place of manufacture, provide at least the city (or administrative region), state (if applicable), and country where the product was manufactured (final assembly)."
  6. Date(s) and place(s) of testing — "Provide the date(s) of the test(s) or test report(s) and location(s) of testing."
  7. Identification of any third-party laboratory who conducted the testing — "Provide at least the name, full mailing address, and telephone number." On when this element can be left blank, the page says: "This section may state 'N/A' for a GCC because third-party laboratory testing is not a requirement for general-use products; however, if the responsible firm uses test results from a third-party laboratory as the basis for issuing its GCC, the law requires that the certifier must then provide information pursuant to this section."

The page also carries a banner: "The guidance listed on this Business Education page may not include information on this new eFiling requirement." For what a certificate has to contain, the current text of 16 CFR 1110.11(a) governs. Its seven items are worded differently from the page's element headings — the product, each rule, the certifier, the records contact, date and place of manufacture, the most recent date and place of testing, and the certifier's attestation.

Format, language and where the GCC goes

No specific form is prescribed. On that point the page says: "No specific template or format need be followed when generating a certificate as long as the 7 required elements are present."

Language is fixed: "The GCC and supporting information must be in English."

Distribution follows the product. CPSC's Testing & Certification page states: "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."

Examples and policy statements on the page

Sample certificates exist for reference, not as templates for every case: "We provide illustrative examples of a GCC for special packaging of aspirin and a mattress. These examples are not intended to capture every possible safety rule that may apply to a general use product."

The page also links two policy documents, identified here by title only:

  • Statement of Policy on Enforcement Discretion Regarding GCC for Adult Wearing Apparel Exempt from Testing (81 FR 12587)
  • Statement of Policy on Enforcement Discretion Regarding GCCs Refrigerators bearing certain safety certification marks (81 FR 12587)

Questions people ask

Do children's products need a GCC?

The General Certificate of Conformity page notes that domestic manufacturers and importers of children's products are subject to different testing and certification requirements, and CPSC's Children's Products page says those products need third-party testing and a written Children's Product Certificate.

Must a GCC be on a particular form?

No. The page states that no specific template or format need be followed as long as the 7 required elements are present.

Can I write "N/A" for the laboratory?

On the page's seventh element, yes, where third-party laboratory testing is not a requirement for general-use products. If the firm bases its GCC on third-party laboratory test results, the law requires the certifier to provide the information.

Where does the certificate have to be?

CPSC's Testing & Certification page says certificates accompany the applicable product or shipment, and a copy must be provided to retailers, distributors and, upon request, to the government.

Sources

Checked 11 October 2026. This page is an unofficial summary and is not affiliated with the U.S. Consumer Product Safety Commission; the official text governs.

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