1. What is CPC certification?
CPC certification means a written child product certificate issued to prove by the manufacturer or importer that its child products comply with all applicable child product safety rules (or in the case of similar rules, prohibitions, standards or any law enforced by the Committee).
Certification of children's products must be based on the results of the pass test of third-party tests. The third party test laboratory provides test services and results, but does not issue child product certificates.
2. Who must issue a child product certificate?
Importers must issue CPC for products produced overseas, while U.S. manufacturers must issue CPC for domestic products.
Manufacturers or importers of children's products that meet the safety rules or other standards of children's products always have the legal responsibility to issue CPC, even if the third party testing laboratory or another third party provides assistance in drafting the CPC.
3. Who is provided with a child product certificate?
If you are a manufacturer or importer, you must "provide" child product certificates to your dealers and retailers. In addition, federal law requires you to provide copies of child product certificates to CPSC and customs director as required.
If the manufacturer or importer provides its distributors and retailers with a reasonable way to obtain the certificate, the requirements of "meeting" the CPC are met. You can provide the actual hard copy of the certificate to dealers and retailers, or you can provide a dedicated website with that specific certificate on the invoice.
4. Where do you need to submit a child product certificate?
CPC must "accompany" the shipment of the product and "deliver" to distributors and retailers. CPC must be provided to CPSC and customs officer as required.
5. What if I sell directly to consumers without using retailers or distributors?
The law requires manufacturers or importers to issue child product certificates; The certificate is accompanied by the shipment of each product or product; The certificate shall be provided to retailers and distributors; And provide certificate to CPSC upon request. Therefore, you do not have to provide certificates to consumers who sell directly to consumers.
6. Does a child product certificate demonstrate that the product complies with multiple child product safety rules?
yes.
For example, if you demonstrate that your product meets the prohibition of phthalate, toy safety standards, total lead content and lead content limits, small parts requirements and other applicable regulations, then your child product certificate section 2 will be as follows:
15 USC 2057c: Determination of phthalates in toys and certain children's products.
ASTM f963-11, consumer safety standard for toy safety.
(Note: you must list the specific number sections of the toy safety standards you want to certify, see all parts listed here.)
15 USC 1278a: lead in children's products
16 CFR Part 1303, lead based coatings and certain consumer goods ban
16 CFR Part 1501 toys and other accessories are not allowed for use in children under 3 years of age, which may be suffocating, mistaking or ingesting.
If your product requires additional mandatory regulations, rules, prohibitions or standards, and currently require third-party testing and certification, you will also include references to the rules, prohibitions or standards of the regulation.
The full title of each of the above requirements is your information only and does not need to be included in your child's product certificate. You only need to include the number reference code that is contained above or in this list.
7. What are the requirements for the certificate of children's products?
The certificate must be based on a laboratory accepted by CPSC and each product must have sufficient samples to pass the test.
8. Does a product require a child product certificate every time it is shipped?
yes. The law requires that each import (and domestic manufacturer) shipment must be accompanied by the required certificate. This requirement is applicable to imported products and domestic products.
According to CPSC rules, if the certificate identifier is identified and accessible through a world wide web URL or other electronic means, the electronic certificate is a "shipped" goods, provided that a URL or other electronic means and identifier is created and shipping is provided.
9. If I import children's products and foreign manufacturers have tested and certified products, do I need to retest or re certify the products? Can I use the certificate of children's products from foreign manufacturers?
CPSC requires that a certificate of conformity be issued by a domestic manufacturer or by an importer of a product manufactured outside the United States. This means that the importer cannot simply pass the certificate of conformity of the foreign manufacturer. However, in 16 CFR 1109, component part testing provides that importers are allowed to use test results from foreign manufacturers or finished certificates for their parts or children's products to issue their own child product certificates, provided that the importer pays attention to ensuring the validity of the test results or certificates and receives documents required by the rules.
10. If I issue a certificate of conformity (a child product certificate or a universal certificate of consistency) on the Internet, do I need to replace it for each shipment, batch, or batch?
If there is no change between each shipment and the previous goods, a single certificate of conformity can be accepted, but the certificate requires the use of batch / batch information or other identification information to describe the date range of the product covered.
A child product certificate may be applicable (or "cover") multiple batches or batches of products, if you have exercised appropriate care to ensure that the production of each additional batch or batch continues to comply with all applicable child product safety rules.
Remember that while a single child product certificate may "cover" more than one shipping or production unit, if the manufacturer chooses to do so, the certificate will need to describe the date range of the product covered, using batch / batch information or other identification information. For each new product or product unit entered into the business flow, the child product certificate will need to be updated to reflect the new product group. Manufacturers of finished children's products will need this information to ensure the accuracy of tracking labels affixed to each child product and its packaging.
11. We are registered with CPSC as "small volume manufacturers". Must I issue a certificate for children's products?
yes. Registered small batch manufacturers must always certify that their children's products comply with the potential child product safety rules applicable to each product.
For those rules in group A, small batch manufacturers must use their child product certificate (CPC) for third-party testing conducted by laboratories accepted by CPSC.
For those rules in group B, qualified small batch manufacturers do not have to issue CPC based on third-party tests, but still must be based on party tests performed by either party, and the CPC issued by the component supplier is provided by a reasonable test procedure or certificate of conformity provided. To indicate that you are involved in the program, the registered small volume manufacturer will list its registration number in sections 6 and 7 of the child product certificate.
12. Is there any penalty for violation of certificate requirements?
yes. In violation of the consumer goods safety law, the failure to provide child product certificates, false certificates of conformity under certain conditions, and non-compliance with Article 14 of the consumer goods safety act. Violation of the "consumer goods safety law" may lead to civil punishment, criminal punishment and asset confiscation.
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