If you are a US based maker of children’s clothing, toys or accessories you will need to ensure that your business is compliant with the rules set out by the Consumer Product Safety Commission (CPSC). One big part of CPSC compliance is Children’s Product Certificates (CPCs).
A CPC is not a document that you buy or can have created for you - it’s something that you as the representative of the business need to create and it needs to contain certain manufacturing information as specified by the CPSC.
The purpose of a CPC is to essentially “certify” that each of your products is created from materials deemed safe to be sold in the US. Although it might sound technical and complicated, it really isn’t as long as you have good records about your material sourcing and manufacturing history: you’re really just creating a short document containing a very simple outline of your product, the regulations that it falls under and the contact details of your business.
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What does the CPC need to include?
In particular, your CPC document must include:
- A description of your product that uniquely identifies it
- Citations of each CPSC children’s product safety rule that is relevant to the product.
- Details about the manufacturer of the product (this would be you if you made the item), including name, mailing address and telephone number.
- Contact information for the individual maintaining records of test results: in a sole proprietorship situation where you have Small Batch registration, this would be your details. If you have someone else on staff specifically maintaining these records their direct contact details should be provided instead.
- Date and place where this product was manufactured. This should be at least the month and year, if you have good manufacturing records then listing the day made would be even better. The place should at minimum include the city, state and country.
- The date and place where the product was tested for compliance with the safety rules. For the Small Batch exemption, this would be when you confirmed that the final manufactured product was compliant - this is usually on the manufacture date.
- Identify any third party, CPSC-accepted laboratory on whose testing the certificate depends. For the Small Batch exemption, this would be your details along with registration number.
Example of a Children’s Product Certificate (CPC)
Now that we have an idea of what is expected in a CPC, let’s go through an example. This example is for a Small Batch Manufacturer that is making a product that is exempt from third party testing.
Important note: The regulations sited in this example are for illustrative purposes only - if using this example as a guideline, you will need to ensure that you are citing the correct regulations that match with your exact product.
- Identification of the product covered by this certificate
Baby bodysuit garment, screenprinted with the words “Hello World!” (SKU B123-HELLOW). Variations in Blue and Yellow.
- Citation to each CSPC product safety regulation to which this product is being certified
16 CFR Part 1610, Standard for the Flammability of Clothing Textiles
15 U.S. Code § 1278a - Children’s products containing lead; lead paint rule
Notes: in this example, your supplier of the blank bodysuit should have also performed testing and have a CPC issued for the component part - you should attempt to obtain this CPC so that you can use this as an additional reference if required.
- Indentification of the U.S. Importer or domestic manufacturer certifying compliance of the product:
Beautiful Babe Handicrafts P.O. Box 283 8562 Fusce Rd. Frederick Nebraska 20620 (372) 587-2335
- Contact Information for the individual maintaining records of test results:
Iris Watson P.O. Box 283 8562 Fusce Rd. Frederick Nebraska 20620 (372) 587-2335
- Date and Place where this product was manufactured
March 2018, Frederick, Nebraska
- Date and place where this product was tested for compliance with the regulations cited above:
March 2018, Frederick, Nebraska, 20620
- Identify the third party, CPSC-accepted where this product was tested by an accredited laboratory for compliance with the regulations cited above:
Small Batch Manufacturer Registration Number 723492343
