Guide · updated 28 October 2026

Sources: CPSA §14, 15 U.S.C. 2063(a) and (g); CPSC final rule Certificates of Compliance, 16 CFR part 1110, 90 FR 1800 (8 January 2025), Federal Register document 2024-30826; 16 CFR part 1107 (third-party testing). Quote-checked against the Federal Register full text.

Children's Product Certificate (CPC) Checklist for Importers

The short answer: the CPC is issued by the manufacturer — which, for an imported product, means you as the importer — or by the private labeler. It is based on third-party testing of the finished product at a laboratory accredited to ISO/IEC 17025 whose accreditation CPSC has accepted, it must list every rule that applies to that product, and since 8 July 2026 its data has to be filed electronically with the customs entry rather than travelling as paper.

1. Who signs the CPC

Section 14(a) of the CPSA puts the certificate obligation on manufacturers, including importers, and private labelers for every consumer product subject to a CPSC rule, ban, standard or regulation (15 U.S.C. 2063(a)(1)). For imported goods the practical consequence is blunt: the factory writes the certificate, but the party that owes it is the importer of record.

For children's products the certificate must be based on third-party testing by a conformity assessment body whose accreditation CPSC has accepted (15 U.S.C. 2063(a)(2); 16 CFR part 1107). The general-product shortcut — a test of each product or a reasonable testing programme (15 U.S.C. 2063(a)(1)(A)) — is not available here. If your supplier cannot name the lab and the accreditation, you do not have a CPC you can rely on.

2. What has to be on the certificate

CPSC's final rule restates the statutory minimum. Every CPC needs all of the following:

1. The issuing party — manufacturer (including importer) or private labeler — and any third-party conformity assessment body whose testing the certificate depends on (15 U.S.C. 2063(g)(1)).
2. Each rule, ban, standard or regulation applicable to the product (15 U.S.C. 2063(a)(1)(B)). Not the standard family — the rules that actually apply.
3. Date and place of manufacture.
4. Date and place of testing.
5. Each party's name, full mailing address and telephone number.
6. Contact information for the individual responsible for maintaining the test records — a person, not a department.
7. Legible, and all content in English (additional languages are allowed) (15 U.S.C. 2063(g)(2)).
8. One product per certificate. The final rule requires each certificate to describe a single product — a family certificate covering several SKUs does not meet it.

3. What "accompany the product" now means

Three obligations run at once, and importers routinely satisfy one and forget the others:

• Accompany the product or shipment, with a copy furnished to each distributor or retailer of the product, and a copy to CPSC on request (15 U.S.C. 2063(g)(3)).
• Filed electronically at entry. Since 8 July 2026 the certificate data goes in with the CBP entry — or the entry and entry summary where both are filed together — through the PGA Message Set in ACE, and may be filed as late as 24 hours prior to arrival. CPSC retains a 24-hour response window when it asks for additional documentation.
• Retained. The certificate and the records behind it have to survive the retention period — five years for GCCs under the final rule, aligned with CBP's own recordkeeping requirement.

The paper certificate still exists as evidence; it is no longer the delivery mechanism. A PDF you can email on request is not the filing.

4. The five fields importers most often get wrong

1. Citing only ASTM F963. CPSC has said directly that citing only F963 on a certificate does not give it enough information, because toys are tested to individual subsections of the standard, not the whole of it. List the subsections your lab actually tested.
2. One certificate for a product family. Bundles, colour variants and "all sizes" certificates get written because it is convenient. The rule asks for a single product per certificate; if you sell a set, the set is the product.
3. A recordkeeper nobody actually monitors. A generic email address and telephone number are allowed under §1110.11(a)(4) — but only if a knowledgeable person actively monitors them and the certifying firm responds within 24 hours of CPSC's first contact. A compliance inbox that routes to a shared queue nobody owns fails that test; the field is fine on paper and dead in practice.
4. The wrong lab. For children's products, testing must come from an ISO/IEC 17025-accredited body whose accreditation CPSC has accepted. A supplier's own in-house report is not that, however professional it looks.
5. The certificate describes the old version. New factory, new mould, revised components, re-branded SKU — the certificate stays as it was. The data filed at entry then describes a product that no longer exists, and the records cannot be tied to the units that were entered.

5. Before your next purchase order

1. Ask for the CPC and the lab report behind it, for the exact product version you are buying — not the previous revision.
2. Check the certificate lists every applicable rule, not just the standard family name.
3. Confirm the named recordkeeper still works for you and can produce the file five years from now.
4. Ask your broker to show the certificate data filed against your last entry, in ACE, not the PDF.
5. If the product can arrive by post, check the Entry Type 13 timeline as well — the entry mechanism and the certificate are two separate obligations.

Related

CPSC eFiling: what importers file, and the 2027 deadline — the filing side, including the 8 January 2027 foreign trade zone date.
Entry Type 13 for international mail: the deadline moved to 20 January 2027 — what postal shipments must file from that date.
Section 15(b): the 24-hour duty to report a defect — the reporting obligation that runs alongside certification.
Button battery recalls and Reese's Law — the compartment, the labels and 16 CFR part 1263.
Magnet ingestion recalls — when the toy standard applies instead of the magnet rule.

Questions

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