What CPSC Certified Really Means (and Why There Is No Such Thing)

Here is a message we get most weeks, give or take the product. A brand has a kids' bath set ready for Amazon US, the factory has sent a PDF headed "CPSC Certificate", and the listing copy already promises "CPSC certified, safe for children". The question is whether that is enough. The honest answer starts with something that surprises people: the US Consumer Product Safety Commission has never certified a single product.

The CPSC writes and enforces safety rules. It accepts laboratories to test against them. It does not look at your product before you sell it, does not hand out certificates and does not keep a list of approved goods. When a listing says "CPSC certified", what it should mean is that the business selling the product has certified it, on its own authority, against the CPSC rules that apply. This guide explains how that works, what changed in July 2026, what you can safely say on a listing, and where cosmetics fit in.

What the CPSC does, and what it does not

The Commission enforces the Consumer Product Safety Act, the Federal Hazardous Substances Act, the Poison Prevention Packaging Act and the Consumer Product Safety Improvement Act (CPSIA). It issues mandatory standards and bans, investigates incidents, negotiates recalls and seeks penalties. Its guidance for online sellers is blunt on the parts sellers get wrong: the CPSC does not provide pre-market approvals, a Children's Product Certificate is not applied for or registered with the agency, and whether a platform accepts your paperwork is a matter between you and the platform.

So there is no form to submit and no number to receive. If someone offers to make your product "CPSC certified" for a fee, what they can really offer is testing, document preparation or advice. The certificate itself has to come from you.

Who actually certifies a product

The certificate rule in 16 CFR Part 1110 answers this directly in section 1110.7. For a product made outside the United States, the importer is the certifier. For a product made in the United States, the manufacturer certifies, except that a privately labeled product is certified by the private labeler unless the manufacturer issues the certificate. That is why a US brand importing a white-label toy cannot leave it to the factory.

CPSC's FAQ goes further. An importer cannot simply pass along a foreign manufacturer's certificate; it must issue its own. It may rely on the factory's test results, but only with due care, under the rules on component testing in 16 CFR Part 1109. The certifier does not have to be located in the US or give a US address. Whoever certifies stays legally responsible for the certificate's accuracy and availability even if a broker, factory or consultant fills it in, which section 1110.15 spells out.

CPC and GCC: the two certificates people mean

For a children's product, meaning one designed or intended primarily for children aged 12 or younger, the certificate is a Children's Product Certificate. It must rest on testing by a third-party lab that the CPSC has accepted for each rule you certify to. More than 600 labs are accepted, but acceptance is rule by rule, so check the scope in the CPSC lab search before you send samples. Our CPSIA guide covers how age is judged and which rules usually apply.

For a general-use product covered by a CPSC rule, the certificate is a General Certificate of Conformity. It must be based on a test of each product or a reasonable testing programme, which can be your own. CPSC's GCC guidance uses special packaging for aspirin as one of its examples, which shows that child-resistant packaging rules sit inside the certificate system too.

A lab report is not a certificate. CPSC says this plainly: passing test reports do not satisfy the certificate requirement. The CPC or GCC is a separate, standalone document.

What changed on 8 July 2026

The Commission rewrote Part 1110 in a final rule published on 8 January 2025 (90 FR 1800), with a technical correction in September 2025. It took effect on 8 July 2026. Products imported from a foreign trade zone follow on 8 January 2027. Two things changed.

Certificate content. Every certificate, domestic or imported, now has to carry the items in section 1110.11: the product and its identifiers, each rule it is certified to, the certifier's name, street address, email and phone, contact details for the person keeping the records, the date and place of manufacture, the date and place of testing with the lab's details, and the certifier's attestation. Each certificate describes one product. It must be in English, though it may also repeat the content in another language.

eFiling for imports. Importers now file certificate data electronically in CBP's ACE system when they file the entry. You can send the full data set in the PGA Message Set, or store it in CPSC's Product Registry and reference it at entry. According to the CPSC eFiling FAQ there is no de minimis exemption, and testing exclusions have to be identified. In the early phase ACE returns warnings rather than rejections, and CPSC says it does not intend to ask for entry to be refused solely because the eFiling is missing. Do not read that as a grace period. Missing data feeds CPSC's risk scoring, and a product that gets examined still needs a valid certificate within 24 hours. US manufacturers do not eFile, but they do have to meet the new content rules, as the CPSC certificates page explains.

Translating the marketing phrases

Most of the confusion comes from a handful of phrases that sound official. This is what each one should mean, if it means anything.

What the listing says	What is actually true
CPSC certified	The importer or manufacturer certified the product in its own CPC or GCC.
CPSC approved	The CPSC does not approve products. Do not use this.
CPSC certificate	A CPC or GCC issued by the company, not by the CPSC.
CPSC certified lab	A lab accepted by the CPSC to test to specific rules. Check the scope for each rule.
CPSC registered	There is no product approval register. The Product Registry is a database for filing certificate data, and 16 CFR 1130 registration cards apply only to durable infant products.
Meets CPSC safety requirements	Acceptable if the product is properly certified and the claim is true.

The Product Registry is worth a word. It is real, and it is CPSC's, but it exists to collect certificate data for imports. A record there is not an approval, any more than filing a customs entry means customs has approved your goods.

Why "CPSC approved" is a legal risk, not just bad wording

CPSC's certification FAQ allows a properly certified children's product to be described as meeting CPSC safety requirements. In the same answer it says firms must not imply that the CPSC tested, approved or endorsed the product, giving "CPSC-approved" as the example to avoid.

There are two legal hooks behind that. First, section 19(a)(6) of the Consumer Product Safety Act (15 U.S.C. 2068) makes it a prohibited act to fail to furnish a required certificate or to issue a false one where, with due care, you would have reason to know it was false or misleading in a material respect. Prohibited acts can lead to civil penalties. Second, a claim of government endorsement that is not true is a representation to consumers, and Section 5 of the FTC Act prohibits deceptive acts in commerce. You do not need a regulator to name your phrase for it to be a problem.

Wording that works: "Tested by a CPSC-accepted laboratory and certified to the applicable CPSC requirements" or "Meets US CPSC safety requirements for children's products. Children's Product Certificate available on request." Both are true if your paperwork is. Our post on claims you cannot make covers the cosmetic side of the same problem.

What marketplaces mean when they ask for "CPSC certification"

When Amazon, Walmart or a big-box buyer asks for "CPSC certification", they want your documents, not a government stamp. Amazon's children's products policy asks for testing by a CPSC-accepted third-party lab and a Children's Product Certificate, accepts only passing reports from samples of the production run, and reserves the right to ask for more. In our experience reviewers also look closely at product images for the tracking label and any required warnings, so make sure the photos match what ships.

CPSC says resellers are not required to issue a CPC. A platform can still require one from you before it lists the product, and that is a contract point the CPSC will not step into. Our guide to marketplace compliance documents sets out what to have ready for each platform, and this one covers what gets listings flagged.

Testing, retesting and records

For children's products the first production batch is tested. After that, 16 CFR Part 1107 requires periodic testing at least once a year for most products, stretching to two or three years only if you meet the conditions in section 1107.21 such as a production testing plan, or ongoing compliance testing with an ISO/IEC 17025 accredited lab. A material change to the design, materials or manufacturing process means new tests for the rules it could affect, and a fresh certificate.

Children's products and their packaging also need permanent tracking labels, to the extent practicable, under 15 U.S.C. 2063(a)(5). Keep your certificates and supporting records for at least five years, furnish the certificate to your distributors and retailers, and be ready to produce it within 24 hours of a request from CPSC or CBP.

Where cosmetics fit

This is where we spend a lot of time with beauty brands. The CPSA definition of consumer product excludes cosmetics, drugs and medical devices, and CPSC's page on products outside its jurisdiction sends cosmetics to the FDA. A face cream or a shampoo does not get a CPC. And the FDA does not approve it either: apart from colour additives, cosmetics need no FDA pre-market approval, while MoCRA adds facility registration and product listing, which are filings rather than approvals. "FDA approved" on a cosmetic has the same problem as "CPSC approved" on a toy.

There are three places where the CPSC does reach beauty products.

• Child-resistant packaging. The Poison Prevention Packaging Act covers some household cosmetics. Under 16 CFR 1700.14(a)(32), non-emulsion liquid cosmetics with at least 10% hydrocarbons and a viscosity under 100 SUS at 100 °F need special packaging. Hydrocarbons here means ingredients made only of carbon and hydrogen, such as mineral oil. The rule exempts packs where the only open access is a spray device and products that cannot flow freely, such as makeup removal pads. Home permanent wave neutralizers containing bromates are covered by a separate entry.
• Toys and kits sold with cosmetics. A toy compact, a doll or a play accessory in a kids' makeup set is a children's product in its own right. It needs testing for lead (including the lead paint limit in 16 CFR 1303), the toy standard ASTM F963-23 made mandatory by 16 CFR Part 1250, small parts where relevant, and a CPC.
• Packaging of children's cosmetics. NIST's guide to US product safety rules notes that the packaging and containers of children's cosmetics are subject to the CPSIA lead limits, even though the cosmetic is not.

Product	Who regulates it	Does it need a CPC or GCC?
Lip balm, shampoo, face cream	FDA (cosmetics)	No. Cosmetics are outside the CPSA definition of consumer product.
Thin, non-emulsion oil-based cosmetic with 10% or more hydrocarbons	FDA for the product, CPSC for the packaging	The child-resistant packaging rule in 16 CFR 1700.14(a)(32) can apply. Check the exemptions and whether a GCC is expected.
Kids' makeup kit with a toy compact or play accessory	FDA for the cosmetic, CPSC for the toy	Yes for the toy and children's components: lead, ASTM F963 and the related tests, then a CPC.
Bath bomb with a hidden toy inside	FDA for the bath bomb, CPSC for the toy	Usually yes for the toy, which is a children's product.
Hairbrush or makeup bag for adults	CPSC (general consumer product)	Only if a specific CPSC rule applies to it.

Product lines like these sit on both sides of the line, so we usually split the file: FDA and MoCRA for the formula and label, CPSC for the toy and packaging. If you also sell in the UK or EU, our side-by-side comparison and the post on why CPNP notification is not an approval show the same pattern. In every one of these systems, the business demonstrates compliance and the regulator enforces it.

How Phoenix helps

We work with brands and importers on the paperwork side of CPSC compliance through our US company, Phoenix Safety Consultants LLC. We map which rules apply to each product, line up testing with a CPSC-accepted lab, draft the CPC or GCC with the Part 1110 content, and prepare the data your broker needs for eFiling. We do not certify on your behalf, and nobody honestly can: the importer or manufacturer signs. What we make sure of is that when you do, the certificate is right. For cosmetic formulas and labels, see our private label compliance guide.

Related reading on the Phoenix blog

• CPSIA explained: US children's product requirements
• Marketplace compliance documents for cosmetics
• Amazon, Etsy and Shopify rules: what gets sellers flagged
• US vs UK and EU cosmetics rules side by side
• MoCRA product listing and facility registration
• CPNP: notification, not approval
• Cosmetic claims you are not allowed to make
• CPSR for baby and children's cosmetics
• Private label and white label cosmetics compliance
• Skin safe formulas and safety certificates

Myths we hear

• A lab can make my product CPSC certified. The lab tests and reports. A CPSC-accepted lab is accepted for specific rules, but the certificate is issued by the importer or manufacturer, who carries the legal responsibility for it.
• My factory in China sent a CPC, so I am covered. CPSC says an importer cannot simply pass along a foreign manufacturer's certificate. You issue your own, though you may rely on the factory's test results if you exercise due care under 16 CFR Part 1109.
• Our CPC is registered with the CPSC. Certificates are not applied for or registered. Since July 2026 importers eFile certificate data at entry, which is a data filing, not an approval.
• A "CPSC compliant" seal on the box proves compliance. No badge has legal standing. Compliance is shown by the certificate and the test records behind it, and a seal that suggests government endorsement can mislead buyers.
• A lipstick needs a CPC. A cosmetic is outside the CPSA definition of consumer product and falls under the FDA. A toy packed with that lipstick, or special packaging required under the Poison Prevention Packaging Act, is a different matter.

What to do this week

1. List every product you sell into the US and decide, for each, whether it is a children's product (designed or intended primarily for children 12 or under) or a general-use product.
2. Map the CPSC rules, bans and standards that apply to each one, including lead, phthalates, ASTM F963 for toys, small parts and any special packaging requirement.
3. For children's products, send production samples to a lab accepted by the CPSC for each of those rules, and keep the passing reports.
4. Issue your own CPC or GCC with the Part 1110 content: product identity, rules, certifier and records contact details, date and place of manufacture and testing, lab details and attestation.
5. If you import, set up eFiling: either the Full PGA Message Set at entry or a Product Registry record referenced at entry, and agree with your customs broker who files what.
6. Put a permanent tracking label on children's products and their packaging to the extent practicable.
7. Plan periodic retesting (at least once a year for most children's products) and retest after any material change.
8. Keep certificates and supporting records for at least five years, and make sure you can produce a certificate within 24 hours of a CPSC or CBP request.
9. Rewrite listings and packaging so they say the product meets the applicable CPSC requirements, never that the CPSC approved or certified it.

Frequently asked questions

Official sources and legislation

• 16 CFR Part 1110: Certificates of Compliance (eCFR, current)
• Federal Register, 90 FR 1800: Certificates of Compliance final rule (8 January 2025)
• Federal Register: Certificates of Compliance, correction (24 September 2025)
• 16 CFR Part 1107: Testing and labeling pertaining to product certification
• CPSC: Children's Product Certificate (CPC)
• CPSC: General Certificate of Conformity (GCC)
• CPSC: Certificates (business guidance on the 2026 changes)
• CPSC: eFiling frequently asked questions
• CPSC: Initial certification testing FAQ
• CPSC: Online sellers safety guide FAQs
• CPSC: Accepted testing laboratory search
• CPSC: Products outside CPSC's jurisdiction
• 15 U.S.C. 2052: definitions, including the cosmetics exclusion
• 15 U.S.C. 2063: product certification and tracking labels
• 15 U.S.C. 2068: prohibited acts
• 15 U.S.C. 45: FTC Act Section 5, unfair or deceptive acts
• 16 CFR Part 1700: Poison prevention packaging
• 16 CFR Part 1250: Safety standard mandating ASTM F963 for toys
• 16 CFR Part 1303: Ban of lead-containing paint
• 16 CFR Part 1130: Product registration cards for durable infant products
• NIST IR 8178r1: Guide to United States product safety requirements (PDF)
• US FDA: How cosmetics are not FDA-approved but are FDA-regulated
• Amazon: Children's products policy and required documents (PDF)