Recently, Amazon's U.S. site mandated that all children's toys and products must have a Children’s Product Certificate (CPC). The CPC is similar to the COC certificate and is required for categories like toys and baby products. Without a CPC, these products cannot be sold.
1. The CPC must be based on test results from a CPSC-recognized third-party laboratory.
2. The CPC is issued by the seller, though third-party labs can assist in drafting it.
3. Children's products must comply with all relevant safety rules and regulations.
4. Information required on the CPC:
- Product information (name and description)
- Applicable regulations and standards
- Manufacturer information: name, address, and phone number
- Production date and location, specifying the city and year/month of manufacture
- Testing time and location
- Third-party testing facility information: name, address, and contact details
1. Product information (name and description)
2. Applicable regulations and standards
3. Importer or U.S. manufacturer information: name, address, and phone number
4. Contact information for the person holding the test results: name, address, email, and phone number
5. Production date and location
6. Testing time and location or the test report the certificate is based on
7. Third-party testing facility information: name, address, and contact details
CPSC has published 38 standards, which include:
1. CPSIA total lead and phthalates
2. ASTM F963 toy safety standard
3. 16 CFR Part 1505 electrical toy safety standard
4. 16 CFR Part 1510 rattle toy requirements
5. 16 CFR Part 1511 pacifier safety standard
6. Flammability standards for children's clothing, carpets, etc., such as 16 CFR Part 1610
7. Standards for infant products like strollers, cribs, playpens, carriers, safety seats, and bicycle helmets
1. CPSIA total lead and phthalates
2. ASTM F963 toy safety standard
3. 16 CFR Part 1501 small parts (covered by ASTM F963 for toys)
4. 16 CFR Part 1510 rattle toy requirements (for rattle toys, covered by ASTM F963)
5. 16 CFR Part 1505 electrical toy safety standard (for electrical toys)
1. CPSIA total lead and phthalates
2. 16 CFR Part 1501 small parts
3. 16 CFR Part 1610 flammability of textiles
4. 16 CFR Part 1615 flammability of children's sleepwear, sizes 0-6X
5. 16 CFR Part 1616 flammability of children's sleepwear, sizes 7-14X
1. CPSIA total lead and phthalates
2. 16 CFR Part 1501 small parts
3. 16 CFR Part 1511 pacifiers
Testing for CPSIA total lead and phthalates is recommended, especially for products like strollers, cribs, playpens, carriers, safety seats, and bicycle helmets.
Ensuring the safety of children's products is crucial, as it impacts economic losses, brand reputation, and most importantly, the safety and well-being of children.
Certification involves issuing a written Children's Product Certificate (CPC), where manufacturers or importers certify that their children's product complies with all applicable safety rules and regulations. The certification must be based on passing test results from a third-party laboratory.
Manufacturers or importers are responsible for drafting and issuing the CPC based on third-party test results. Importers must issue CPCs for overseas-produced products, while U.S. manufacturers issue CPCs for domestically produced products.
Creating a CPC does not incur any fees. It can be drafted using a word processing document or other systems. No cost is required for government submission of the CPC, and CPSC offers a free small business ombudsman for assistance.(Email:hello@jjrlab.com)
Manufacturers or importers must provide the CPC to their distributors and retailers. The CPC must also be available to the CPSC and the Customs Director upon request.
There is no requirement to submit the CPC to the government. The CPC must accompany the product shipment and be available to distributors, retailers, the CPSC, and Customs upon request.
If selling directly to consumers without using retailers or distributors, manufacturers or importers do not need to provide the CPC to the consumers.
CPSC provides a sample CPC and a model to guide the drafting process, though manufacturers can create their own as long as it meets all requirements.
A CPC can certify compliance with multiple safety rules and regulations for a product.
The certificate must be based on passing test results from sufficient product samples tested by a CPSC-accepted laboratory.
A CPC is required for each product shipment, whether imported or domestically manufactured. Electronic certificates are acceptable if they meet specific criteria.
Importers cannot pass through a foreign manufacturer's CPC but can use foreign test results or certificates for their own CPC issuance, provided they ensure the validity of the results.
Electronic certificates are permitted if they meet all legal requirements and are accessible to the CPSC.
A single CPC can cover multiple batches or shipments if there are no significant changes. The certificate must describe the product date range covered.
The CPC does not require a signature. Issuing the certificate itself is a legal compliance act.
Small batch manufacturers must certify their products comply with applicable safety rules and can base their CPC on first-party testing or other qualifying results.
Violations of CPC requirements can result in civil and criminal penalties and asset forfeiture.
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