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USCPSC Compliance

# CPSC Consumer Product Safety

The Consumer Product Safety Commission (CPSC) enforces federal safety standards for consumer products through the Consumer Product Safety Act and CPSIA. Understanding certificate requirements, testing obligations, and recordkeeping rules is essential for legal market entry.

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At a glance

Certificate types

2

CPSIA requirements

4

Compliance steps

6

## Certificate types

### Children's Product Certificate (CPC)

Required for all children's products defined by CPSIA. Must be based on third-party testing by CPSC-accepted laboratory and issued by the manufacturer or importer.

Applies to: Children's toys, childcare articles, children's clothing, children's jewelry, and any product designed or intended primarily for children 12 years and younger

Testing: Third-party testing by CPSC-accepted laboratory mandatory

Retention: Retain certificate and test reports for 5 years

### General Certificate of Conformity (GCC)

Required for non-children's consumer products subject to CPSC consumer product safety rules. Can be based on manufacturer's own testing or reasonable testing program.

Applies to: General consumer products subject to CPSC rules such as furniture, appliances, household products, and adult clothing (when subject to specific rules)

Testing: Reasonable testing program - can be in-house or third-party

Retention: Retain certificate and supporting records for 5 years

## Key CPSIA requirements

### Lead Content Limits

Children's products must not contain more than 100 ppm lead in accessible substrate materials. Paint and coatings limited to 90 ppm lead.

**Applies to:** All children's products - toys, jewelry, clothing, furniture, etc.

### Phthalates Limits

Eight specific phthalates are prohibited or limited in children's toys and childcare articles that can be placed in a child's mouth.

**Applies to:** Children's toys and childcare articles (especially those for mouth use)

### Tracking Labels

Each children's product must have a permanent distinguishing mark or label including date of production and batch information.

**Applies to:** All children's products manufactured after August 14, 2009

### Toy Safety Standard (ASTM F963)

Mandatory federal toy safety standard covering mechanical hazards, flammability, toxic substances, electrical safety, and labeling.

**Applies to:** All toys designed or intended for children under 12 years

## Compliance process steps

01

Identify applicable CPSC rules

Determine which CPSC consumer product safety rules apply to your product based on its category, intended use, and target user group.

02

Determine certificate type

Classify whether your product is a children's product requiring CPC or a general consumer product requiring GCC.

03

Arrange required testing

For children's products: contract CPSC-accepted laboratory for third-party testing. For general products: establish reasonable testing program.

04

Compile test reports

Gather all required test reports showing compliance with applicable CPSC rules and standards.

05

Issue certificate

Create CPC or GCC including all required elements: product identification, applicable rules, testing dates, and issuer information.

06

Maintain records

Retain certificates and test reports for 5 years and make them available to CPSC upon request.

## Common compliance mistakes

Misclassifying products as general instead of children's products - CPSIA definition is broader than obvious toys

Using non-CPSC-accepted laboratories for children's product testing - third-party testing must be from accepted labs

Incomplete CPC/GCC content - missing required elements like dates, contact information, or specific rule citations

Not maintaining test reports for full 5-year retention period

Missing tracking labels on children's products - permanent batch/date marking is mandatory

Assuming ASTM F963 compliance is sufficient - it's mandatory but not the only requirement for toys

## Frequently asked questions

### What is the difference between a CPC and GCC?

A Children's Product Certificate (CPC) is required for products primarily intended for children 12 and under, and must be based on third-party testing by a CPSC-accepted laboratory. A General Certificate of Conformity (GCC) is for general consumer products and can be based on a reasonable testing program that may include in-house testing. The testing requirements and documentation standards are significantly different.

### How do I know if my product is considered a children's product?

CPSC defines a children's product as a consumer product designed or intended primarily for children 12 years of age or younger. Factors include: manufacturer's stated intent (labeling, advertising), product design, and whether the product is commonly recognized as intended for children. When in doubt, treat it as a children's product to ensure compliance.

### Do I need CPSC-accepted laboratory for all testing?

Only for children's products requiring CPC. Third-party testing for children's products must be performed by laboratories accredited by CPSC-accepted accreditation bodies. For general consumer products (GCC), you may use in-house testing or third-party labs that are not CPSC-accepted, as long as you have a reasonable testing program.

### What records must I keep and for how long?

You must retain certificates (CPC or GCC) and all supporting test reports for 5 years. Records must be available for inspection by CPSC upon request. This includes the actual test reports, not just summary certificates. For imported products, the importer must also maintain these records.

### Are there exemptions from third-party testing requirements?

Yes, CPSC has granted certain exemptions for specific materials and products where lead content is inherently below limits or testing is impractical. Examples include certain natural materials (wood, cotton) without additives, and some electronic components. Always verify current exemption status before relying on them.

**Disclaimer:** This guide provides general information about CPSC requirements. Product-specific determinations require analysis of applicable CPSC rules. Always verify current requirements with CPSC resources or qualified compliance professionals.

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