CPSC: The Importer Issues the CPC

For a finished product made outside the United States, the importer issues the certificate. 16 CFR 1110.7(a), as of 10 November 2026, says the importer, as part 1110 defines that term, must issue the finished product certificate unless a specific CPSC rule provides otherwise. Part 1110 calls a children's-product certificate a Children's Product Certificate (CPC) and the certificate for other finished products a General Certificate of Conformity (GCC). A children's product, under 15 U.S.C. 2052, is one designed or intended primarily for children 12 years of age or younger. Total lead in a children's product is 100 parts per million by weight under 15 U.S.C. 1278a, unless the Commission determines that limit is not technologically feasible for the product or category. Paint is separate: 16 CFR 1303.1 bans surface coatings above 0.009 percent lead, effective 14 August 2009.

Diagram stating that the importer issues the children's product certificate for goods made outside the United States, with the age-12 and 100 ppm lead lines. — Importer duty from 16 CFR 1110.7(a). Age from 15 U.S.C. 2052. Lead from 15 U.S.C. 1278a. As of 10 November 2026.

Send the SKU and who the importer of record will be so the file names the certifier before the factory prints a certificate in its own name.

Illustrative shipment file

The rows below are an illustrative example. The identifiers, the lot code, and the laboratory name are assumptions, not a real inspection and not a real certificate. The legal tests in the last column are the official ones.

Illustrative example. Values in the middle column are assumptions, not a real file.
Slot	Illustrative assumption	Official test
Who certifies	Northwind Imports LLC, the importer of record	16 CFR 1110.7(a): for goods manufactured outside the United States, the importer issues the certificate.
Product	Plush fox, model FOX-14, lot B12	16 CFR 1110.11: at least one unique identifier plus a description that matches the goods.
Children's product?	Sold as a toy for ages 3 and up	15 U.S.C. 2052: designed or intended primarily for children 12 or younger.
Testing	A named CPSC-accepted body, report ID assumed	15 U.S.C. 2063 and 16 CFR 1107.20: third party testing on enough identical samples.
Lead	Do not type a result here until the report exists	100 ppm total lead, unless the Commission sets a different feasible limit for the category. Paint: 0.009 percent.
Tracking	Sew-in: maker, place, date, lot B12	15 U.S.C. 2063: permanent distinguishing marks on the product and the packaging, to the extent practicable.

Replace every assumed cell with the real importer, identifier, and test report before anyone calls this a CPC.

What the statute still requires underneath

15 U.S.C. 2063 requires the children's-product certificate to rest on testing by an accredited third party conformity assessment body. A factory bench sheet is the input to that body, not the certificate. Section 1110.7(b), which names the US manufacturer or the private labeler, applies to finished products manufactured in the United States. It is the wrong row for a Yiwu shipment. How to look at the goods on the market floor is on Yiwu baby and kids products. The customs entry is on importing from China to the United States. A visual pre-shipment pass is not the CPC: see when a PSI pass is not a safety certificate.

Figure showing the paint lead limit of 0.009 percent effective 14 August 2009. — 16 CFR 1303.1, as of 10 November 2026. This is paint, not the 100 ppm total-lead line.

What buyers ask

Can the Chinese factory sign the CPC?

Not for goods manufactured outside the United States. 16 CFR 1110.7(a) assigns the certificate to the importer, unless a specific CPSC rule says otherwise. The factory can produce the samples and the tracking marks. It does not become the certifier by signing the PDF.

Is 100 ppm automatic for every toy?

Section 1278a sets 100 parts per million total lead, and it allows the Commission to set a different limit where 100 ppm is not technologically feasible for that product or category. Quote the exception with the number. Paint stays at 0.009 percent under 16 CFR 1303.1.

Name the children's product and the US importer on the RFQ if the certificate holder should be fixed before sampling.

Sources

eCFR: 16 CFR 1110.7. As of 10 November 2026. Importer issues the certificate for goods made outside the United States.
eCFR: 16 CFR part 1110. CPC and GCC definitions, and certificate content. Source note 90 FR 1843, 8 January 2025.
15 U.S.C. 2052 and 15 U.S.C. 2063. 2023 edition. Definition, third party testing, tracking marks.
15 U.S.C. 1278a and 16 CFR 1303.1. 100 ppm total lead, and 0.009 percent in paint from 14 August 2009.

CPSC Rules for Children's Products from China