ComplyMyImport guide

Children's Product Certificate Guide for US Importers

A Children's Product Certificate, commonly called a CPC, is the document in which a responsible domestic manufacturer or importer certifies that a children's product complies with each applicable children's product safety rule. For products manufactured outside the United States, the importer is generally responsible for issuing the CPC.

A CPC is not a laboratory report. It is based on applicable passing test results from a third-party laboratory accepted by the US Consumer Product Safety Commission for the relevant testing scope. The importer remains responsible for determining which rules apply and for ensuring that the certificate is accurate.

Which products may need a CPC?

Children's products are products designed or intended primarily for children 12 years of age or younger. A children's product that is subject to one or more CPSC-enforced children's product safety rules generally requires third-party testing and certification.

The requirements vary with the product. Age grading, materials, accessible components, intended use, design, and manufacturing details can all affect the applicable rule set. A test report for one model, material, factory, or production period should not automatically be treated as evidence for another.

The seven CPC elements

CPSC guidance identifies seven elements that must be present and accurate:

• Identification of the product covered by the certificate
• Each applicable children's product safety rule
• The domestic manufacturer or importer certifying the product
• The person maintaining the supporting test records
• The date and place of manufacture
• The date and place of testing
• Each third-party CPSC-accepted laboratory that performed testing

The product description should be specific enough to connect the CPC to the covered product and no others. Rule citations should reflect the product's actual applicability analysis. For toys subject to ASTM F963 through 16 CFR part 1250, CPSC guidance calls for the applicable ASTM F963 sections rather than only a broad reference to part 1250.

Evidence to collect before preparing a CPC

An importer should be able to connect every certificate field and rule citation to reliable product records. A practical evidence package may include:

• Product name, model, SKU, and variant identifiers
• Intended age range and use
• Bill of materials and component details
• Factory name and complete manufacturing location
• Production date or date range
• Complete test reports and testing dates
• Laboratory name, address, contact details, and applicable CPSC scope
• Tracking-label artwork and production identifiers
• Records of material, supplier, factory, or design changes

Collecting only a supplier's certificate can leave important gaps. Importers should confirm that the underlying reports cover the correct finished product and applicable requirements.

Common CPC preparation problems

Frequent problems include a report for the wrong model, incomplete rule citations, a laboratory without the required facility-specific scope, missing manufacturing details, and testing that predates a material change. Another common issue is treating a draft assembled from extracted data as an issued certificate.

ComplyMyImport organizes product records, source-linked evidence, applicability results, and certificate fields in one review workflow. AI can assist with extracting information, but it does not make the final legal determination or issue a CPC. An authorized customer representative must review and approve the certificate.

Prepare before the shipment moves

The best time to resolve a certificate gap is before goods are booked or arrive at the port. Build the product record early, request missing evidence from the supplier, verify laboratory scope, and give the authorized representative time to review the completed certificate data.

This guide is general educational information and is not legal advice. Consult current CPSC requirements and qualified counsel for decisions about a particular product.

Official resources

• CPSC Children's Product Certificate guidance: cpsc.gov/cpc
• CPSC rules requiring third-party testing: cpsc.gov/Business--Manufacturing/Testing-Certification/Lab-Accreditation/Rules-Requiring-Third-Party-Testing
• CPSC laboratory search and accreditation guidance: cpsc.gov/labsearch