Guide
US certificates of conformity: GCC vs CPC and CPSC eFiling
Which consumer products need a General Certificate of Conformity or a Children’s Product Certificate, who must issue it, what it must contain under 16 CFR 1110, and how certificate data is now eFiled at import.
In the United States, many consumer products regulated by the Consumer Product Safety Commission (CPSC) must be certified as compliant before they are imported or distributed. The certificate is a short document, but it has a fixed set of required elements, it must be backed by testing, and since 8 July 2026 importers must eFile its data with US Customs and Border Protection (CBP) for most covered imports.
This guide explains the two certificate types, the required content under 16 CFR part 1110 as revised in January 2025, and what the eFiling rule changes. It is general information, not legal advice; check the current eCFR text and CPSC guidance, and seek qualified advice for your products.
What a US certificate of compliance is
A certificate of compliance is the certifier’s written statement, based on testing, that a product meets every CPSC rule, ban, standard, or regulation that applies to it. 16 CFR part 1110 calls these “certificates of compliance”; CPSC guidance calls the two types the General Certificate of Conformity (GCC) and the Children’s Product Certificate (CPC).
Unlike an EU declaration, there is no single US certificate for every product. A certificate is needed only where a CPSC-enforced rule applies, and it lists those rules one by one. It is issued by the US importer or domestic manufacturer, not by a lab or a government agency, and it must be in English; other languages may be added, but eFiled certificates must be in English (§ 1110.9(a)).
GCC vs CPC: the key differences
The deciding question is whether the product is a children’s product: one designed or intended primarily for children 12 years or younger. If it is, it needs a CPC based on third-party testing. If not, and a CPSC rule applies, it needs a GCC.
| Aspect | GCC | CPC |
|---|---|---|
| Legal basis | CPSA § 14(a)(1) | CPSA § 14(a)(2) |
| Products | General-use products subject to a CPSC rule, ban, standard or regulation | Children’s products for ages 12 or younger subject to a CPSC rule |
| Testing basis | A test of each product or a reasonable testing program | Testing by a CPSC-accepted third-party lab (16 CFR 1107) |
| Third-party lab | Not required; identify it if you relied on one | Required |
| Periodic testing | Per the certifier’s testing program | At least yearly; 2 or 3 years under the conditions in § 1107.21 |
| Who issues | Importer, or domestic manufacturer or private labeler | Same as GCC |
| Required content | Seven elements under § 1110.11 | Same seven elements |
| eFiling at import | Required for covered imports | Required for covered imports |
When a certificate is required and who must issue it
Under § 1110.5, a certificate is required for finished products that are subject to a consumer product safety rule under the Consumer Product Safety Act, or to a similar rule, ban, standard, or regulation under any other law the CPSC enforces, and that are imported for consumption or warehousing or distributed in commerce. A general-use product that no CPSC rule covers needs no certificate, and the eFiling rule does not require a disclaimer message for such products.
For children’s products, typical applicable rules include the toy standard ASTM F963-23 (16 CFR 1250), the 100 ppm total lead limit for accessible substrate (15 U.S.C. 1278a), the 90 ppm lead limit for paint and surface coatings (16 CFR 1303), and the 0.1% limit for eight phthalates in children’s toys and child care articles (16 CFR 1307). Which rules apply depends on the product.
Who certifies is set by § 1110.7:
- Imported products: the importer, meaning the importer of record. A broker acting as importer of record may name the owner, purchaser, or consignee as the certifier.
- Products made in the US: the manufacturer, or the private labeler for privately labelled products unless the manufacturer certifies.
- Foreign factories and suppliers: their test reports and component data feed the certificate, but the importer remains responsible for issuing it.
- Component parts: component-part certificates are voluntary (§ 1110.19), but they can support the finished-product certificate.
The seven required certificate elements
Section 1110.11(a) lists seven elements that every GCC and CPC must contain. The examples below show the level of detail expected; replace them with your own data.
| Element | What to include | Example |
|---|---|---|
| 1. Product identification | At least one unique identifier (GTIN, model, registered or serial number, SKU, UPC, or alternate) plus enough description to match the product; lot, style, colour optional | Plush rabbit, model KT-12, SKU KT12-GRY, plus its GTIN |
| 2. Applicable rules | Each rule, ban, standard, or regulation, listed separately | 16 CFR 1250 (ASTM F963-23); 16 CFR 1303; 16 CFR 1307 |
| 3. Certifier identity | Name, street address, city, state or province, country, email, and telephone | The importer of record’s legal name and full contact details |
| 4. Records custodian | Name or a permanently staffed position title, full address, email, and telephone | Compliance Manager, with address, email, and phone |
| 5. Date and place of manufacture | At least month and year; manufacturer name, full address, email, telephone; first date for multi-day runs | March 2026; factory name and full contact details |
| 6. Date and place of testing | Most recent date and place(s) of testing; each lab or other party relied on, with full contact details | Lab name, address, email, phone; test date |
| 7. Attestation | The prescribed attestation, including that knowingly false statements are a federal crime | Built into the Product Registry and PGA message set when eFiled |
Other certificate rules that trip people up
Beyond the seven elements, part 1110 sets several practical rules. Most problems at import come from these, not from the main fields.
- One product per certificate (§ 1110.13(a)): do not cover a whole range with one document.
- Testing exclusions: where a statutory or regulatory exclusion means a requirement was not tested, identify the exclusion in place of test data (§ 1110.11(c)).
- Optional link: a URL to the underlying records is allowed (§ 1110.11(b)).
- Furnishing: the certificate must be furnished to distributors and retailers and made available to CPSC or CBP within 24 hours of a request.
- Records: keep them for at least 5 years from the date the certificate was created (§ 1110.17).
- Language: English, with other languages optional, while eFiled certificates must be in English (§ 1110.9(a)).
Third-party testing for children’s products
A CPC must rest on testing by a CPSC-accepted third-party conformity assessment body (16 CFR 1107.20; definition in § 1110.3). Testing is not a one-time event: periodic testing must continue while the product is produced, and retesting is required after a material change (§ 1107.23).
CPSC guidance also describes tracking labels for children’s products: permanent marks on the product and its packaging, to the extent practicable, identifying the manufacturer or private labeler, the location and date of production, and batch or run information. Check CPSC’s tracking-label guidance for details.
| Situation | Minimum periodic testing |
|---|---|
| Default | At least once a year |
| With a production testing plan | Every 2 years |
| Continued-compliance testing at an ISO/IEC 17025-accredited lab | Every 3 years |
| Material change to the product | Retest before certifying the changed product (§ 1107.23) |
CPSC eFiling: what changed and when
The final rule published on 8 January 2025 (90 FR 1800) requires importers to eFile the § 1110.11 certificate data elements in CBP’s Automated Commercial Environment (ACE) at the time of entry, or at entry and entry summary if filed together, using CPSC’s PGA Message Set (§ 1110.13(a)(1)).
The requirement covers products entered from a foreign trade zone (FTZ) and de minimis (Section 321) entries, so low-value shipments are included. For mail imports, the data must be entered in the CPSC Product Registry before the goods arrive.
| Date | What happens | Applies to |
|---|---|---|
| 8 Jan 2025 | Final rule published (90 FR 1800) | Revised 16 CFR part 1110 |
| 8 Jul 2026 | eFiling of certificate data becomes mandatory | All covered products, including de minimis entries |
| 8 Jan 2027 | eFiling becomes mandatory for FTZ goods | Products imported into an FTZ, then entered for consumption or warehousing |
eFiling options and CPSC’s enforcement approach
The rule allows two ways to file at entry: send the full certificate data, or reference a certificate stored in CPSC’s Product Registry. Mail imports and products outside CPSC rules are handled differently, as the table shows.
On enforcement, the preamble says that, at least in the initial stages of eFiling, CPSC in general does not intend to ask CBP to deny entry solely because eFiled data is missing. That is not an exemption: CPSC says it will still use refusal of admission, seizures, and risk scoring, and incomplete data may affect how a shipment is treated. We found no CPSC announcement delaying the 8 July 2026 date; check CPSC’s eFiling page for updates.
| Option | How it works | Typical fit |
|---|---|---|
| Full PGA Message Set | All certificate data elements are sent with the entry in ACE | Low volume or frequently changing products |
| Reference PGA Message Set | The entry points to a certificate stored in the CPSC Product Registry | Repeat imports of the same product |
| Product Registry (mail) | Certificate data entered in the Registry before arrival | Products imported by mail |
| No message | No certificate and no disclaimer message needed | Products not subject to any CPSC rule |
How to prepare a certificate step by step
The order below works for both GCCs and CPCs. For imports, finish it before the goods ship so the data is ready for the entry filing.
Doc2Shelf can help with the paperwork side: it extracts identifiers, manufacturer details, and test-report references from supplier documents and drafts a US declaration for toys for review, flagging missing items as [REQUIRED] placeholders. It does not test products, file data with CBP or CPSC, or certify anything; the importer or manufacturer remains the certifier.
- Classify the product: is it a children’s product (primarily for ages 12 or younger) or general-use?
- List every CPSC rule, ban, standard, or regulation that applies. If none applies, no certificate is required.
- Arrange testing: a CPSC-accepted third-party lab for children’s products; for general-use products, a test of each product or a reasonable testing program.
- Collect the data: unique identifier, manufacturer name and contact details, month and year of manufacture, lab details and most recent test date.
- Name the certifier (the importer of record for imports) and the records custodian.
- Draft one certificate per product with all seven elements, identifying any testing exclusions.
- Decide how you will eFile: full data with each entry, or a Product Registry certificate referenced in the entry.
- Share the certificate with your customs broker, distributors, and retailers, and file the supporting records for at least 5 years.
- Review the certificate whenever the product, factory, or applicable rules change, and retest after a material change.
Common certificate mistakes
These are the errors most often found when certificates are compiled from supplier paperwork.
| Mistake | Why it matters | Fix |
|---|---|---|
| The factory issues the certificate | For imports, the importer certifies | Issue it in the importer of record’s name |
| One certificate for a whole product range | Each certificate covers one product | Create one certificate per product |
| Rules grouped as “CPSIA compliant” | Each rule must be listed separately | List each rule, ban, or standard |
| CPC based on in-house testing | Children’s products need a CPSC-accepted lab | Use an accepted third-party lab |
| No email or phone for the certifier or custodian | Contact details are required elements | Add full address, email, and phone |
| Only a year of manufacture | At least month and year are required | Add the month, or the first date of a run |
| Old test report after a material change | Retesting is required | Retest and update the certificate |
| Ignoring de minimis shipments | eFiling covers Section 321 entries | Prepare data for low-value shipments too |
Frequently asked questions
- What is the difference between a GCC and a CPC?
- A GCC covers general-use products subject to a CPSC rule and may rest on a reasonable testing program without a third-party lab. A CPC covers children’s products for ages 12 or younger and must be based on testing by a CPSC-accepted third-party lab. Both need the same seven elements.
- Does every product imported into the US need a certificate?
- No. A certificate is required only for products subject to a CPSC-enforced rule, ban, standard, or regulation (§ 1110.5). Products with no applicable CPSC rule need no certificate, and no eFiling disclaimer message is required for them.
- Who issues the certificate for imported products?
- The importer of record. A broker acting as importer of record may name the owner, purchaser, or consignee. The foreign factory supplies test reports and data but is not the certifier (§ 1110.7).
- Can a General Certificate of Conformity be based on in-house testing?
- Yes. A GCC may rest on a test of each product or a reasonable testing program, and third-party testing is not required. If you relied on a third-party lab, it must be identified on the certificate.
- When did CPSC eFiling become mandatory?
- On 8 July 2026 for covered products. Products imported into a foreign trade zone and later entered for consumption or warehousing follow from 8 January 2027.
- Do de minimis shipments need eFiled certificate data?
- Yes. The eFiling rule covers de minimis (Section 321) entries. For mail imports, the certificate data must be entered in the CPSC Product Registry before arrival.
- Will CBP refuse a shipment if eFiled data is missing?
- CPSC said that, at least initially, it generally does not intend to ask CBP to deny entry solely for missing eFiled data. It still uses refusal of admission, seizures, and risk scoring, so missing data carries real risk.
- How long must certificate records be kept?
- At least 5 years from the date the certificate is created (§ 1110.17). The certificate itself must be made available to CPSC or CBP within 24 hours of a request.
Official sources
Primary legal texts and official guidance referenced in this guide.
- CPSC certificates of conformity — 16 CFR Part 1110 (eCFR)
- Certificates of Compliance final rule (eFiling) — 90 FR 1800 (Federal Register)
- CPSC eFiling (U.S. Consumer Product Safety Commission)
- General Certificate of Conformity (U.S. Consumer Product Safety Commission)
- Testing and labeling pertaining to product certification — 16 CFR Part 1107 (eCFR)
- Safety standard for toys (ASTM F963) — 16 CFR Part 1250 (eCFR)
- Lead-containing paint ban — 16 CFR Part 1303 (eCFR)
- Phthalates prohibition in children’s toys and child care articles — 16 CFR Part 1307 (eCFR)
- Tracking labels for children’s products (U.S. Consumer Product Safety Commission)
This guide is general information, not legal advice. Requirements depend on the product and market; check the official texts and seek qualified advice for your situation.