Can I write my own Children’s Product Certificate?
Yes. The importer or U.S. manufacturer drafts and issues the CPC; the lab tests but does not issue it. CPSC prescribes no form, charges nothing and approves nothing: any document with the seven elements of 16 CFR 1110.11 works, based on passing tests from a CPSC-accepted lab. You stay legally responsible, whoever drafts it.
What CPSC says
The lab provides the testing and results but does not issue the CPC; the manufacturer, importer or private labeler drafts and issues it. Creating one has no cost — word-processing software will do — and no signature is required. The certifier is legally responsible even when a lab or another third party drafts it CPSC CPC FAQ. There is nothing to apply for or register CPSC online sellers FAQ.
The seven elements, since July 8, 2026
| Element | What to write |
|---|---|
| 1. Product | At least one identifier — GTIN, model, registered or serial number, SKU, UPC or an alternate ID — and a description that matches the product |
| 2. Rules | Each applicable rule separately; a testing exclusion named where it replaces a test |
| 3. Certifier | Name, street address, city, state or province, country, email and phone |
| 4. Records keeper | A person, or a position that is always staffed, with the same details |
| 5. Manufacture | Month and year at least, and the factory’s name, address, email and phone |
| 6. Testing | Most recent test date, and each lab relied on, with contact details |
| 7. Attestation | For paper and electronic certificates, the regulation’s own wording |
All seven: 16 CFR 1110.11. The certificate is in English 16 CFR 1110.9(a).
Gaps to check before you issue it
- An old template: CPSC’s own CPC guidance page still lists the earlier elements and warns it may not reflect the eFiling changes CPSC CPC guidance.
- A lab that is not CPSC-accepted for the test cited 16 CFR 1107.2.
- Several products on one certificate: each describes only one product 16 CFR 1110.13(a).
- A rule dropped because an exclusion applies: the rule stays listed and the exclusion replaces the test 16 CFR 1110.11(c).
- Only the lab report handed over: it is the foundation, not the CPC CPSC online sellers FAQ.
Writing it yourself is free and allowed. If you would rather not, we write it from your lab reports, check every rule and exclusion, and add the Registry import file and broker sheet: $79 per product, 2 U.S. business days. You review it and issue it.
Last reviewed: September 30, 2026 · First published: September 30, 2026 · Not legal advice.
Sources read September 30, 2026
- CPSC, Children’s Product Certificate (CPC) FAQ
- CPSC, Online Sellers Safety Guide FAQs
- 16 CFR 1110.11 — Certificate content
- 16 CFR 1110.9 — Certificate language and format
- CPSC, Children’s Product Certificate guidance
- 16 CFR 1107.2 — Definitions (material change, third party conformity assessment body)
- 16 CFR 1110.13 — Certificate availability and eFiling