Can I use my supplier’s CPC, or do I need my own?

The rule

For imported products, the importer is the certifier 16 CFR 1110.7(a). CPSC puts it plainly: an importer “cannot simply pass along a foreign manufacturer’s certificate” CPSC CPC FAQ, and the final rule says the certifier “must still issue their own certificate” 90 FR 1800. Relying on another party’s testing or certification is allowed, and you stay legally responsible 16 CFR 1110.15.

Get these before you rely on them

You must not rely on another party’s certificate or reports unless you receive this documentation 16 CFR 1109.5(g), (i)(3):

• identification of the product or component tested, and its lot or batch;
• the rules it was tested to, the test methods and sampling protocols;
• the test dates and test reports, with values;
• who tested, with their attestation that testing followed section 14 of the CPSA and part 1107;
• any component or finished product certificates, traceability records, and a custody attestation.

Without them, CPSC may consider that you failed to exercise due care, and then it does not consider you to hold a valid certificate 16 CFR 1109.5(i)(2).

Checks that catch most problems

• Each lab is CPSC-accepted for the tests it ran 16 CFR 1107.2 CPSC lab list. A lab recognized for another agency’s program does not qualify by that alone.
• The sample tested is the product you import, or identical in all material respects 16 CFR 1107.20(a).
• The report is recent enough for your periodic-testing interval: at least once a year, unless a production testing plan or continued ISO/IEC 17025 testing applies 16 CFR 1107.21.
• The factory on the report made your goods: certification test records are kept per manufacturing site 16 CFR 1107.26(a)(2).
• Your certificate names each lab relied on, including labs that tested components 16 CFR 1110.11(a)(6).