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Importer cannot pass along a factory CPC: issue your own certificate

CPSC requires the domestic manufacturer or importer to issue the CPC. You may rely on another party's testing under 16 CFR 1109 with due care, but you still issue your own certificate.

CPSC's CPC page states that domestic manufacturers and importers of children's products must certify in a written Children's Product Certificate, based on test results from a third-party CPSC-accepted laboratory. The CPC and supporting test reports must be in English.

16 CFR part 1109 lets a finished-product certifier rely, in whole or in part, on another party's finished-product or component-part testing or certification if the certifier exercises due care and receives the documentation listed in § 1109.5(g). That does not replace your duty under part 1110 to issue the finished-product certificate in the importer's (or domestic manufacturer's) name.

CPSC's seven required CPC elements:

1. Product identification
2. Each children's product safety rule cited
3. Importer or domestic manufacturer: name, full mailing address, phone
4. Records contact: name, email, full mailing address, phone
5. Date (at least month/year) and place of manufacture
6. Date and place of testing
7. Third-party CPSC-accepted lab: name, full mailing address, phone

First actions

1. Do not submit the factory's CPC as if it were yours.
2. Get the full underlying test report and the documentation 16 CFR 1109.5(g) lists.
3. Issue a new CPC naming your company as importer (or domestic manufacturer), with your contact details.
4. Check the product identifier, rules and lab match the report and the listing.
5. Run the free document-vs-listing check before you resubmit.

Free check: does your CPC match your listing? →

Official sources

• CPSC: Children's Product Certificate
• eCFR: 16 CFR part 1110 (Certificates of Compliance)
• eCFR: 16 CFR part 1109 (relying on another party's testing or certification)

General information, not legal advice. Platform rules change; the linked official pages are the authority.