Key takeaways
- For goods made in India, the US importer is the party that must issue the certificate, even when the factory arranges the testing.
- General-use products need a GCC based on a test of each product or a reasonable testing program. Children's products need a CPC based on testing by a CPSC-accepted lab.
- Paint on any consumer furniture, and on children's products, must not exceed 90 ppm lead (16 CFR 1303).
- Since 8 July 2026 importers must eFile certificate data with CBP at entry. eFiling added no new testing duties.
- An inspection checks labels, construction and documents against the certificate; the tests behind it need a lab.
How CPSC rules work for imports
CPSC enforces the Consumer Product Safety Act (CPSA), the Federal Hazardous Substances Act, the Flammable Fabrics Act and related laws. The Consumer Product Safety Improvement Act of 2008 (CPSIA) amended them and made certification the backbone of the system.
Under 16 CFR 1110, every finished consumer product that is subject to a CPSC rule, ban, standard or regulation must be accompanied by a certificate. For a product made outside the US, the importer is the party that must issue it. The certificate must be in English, list each applicable rule separately and be available to CPSC or US Customs and Border Protection (CBP) within 24 hours on request. The importer must keep the certificate and the test records behind it for at least five years.
| General Certificate of Conformity (GCC) | Children's Product Certificate (CPC) | |
|---|---|---|
| Applies to | General-use products subject to a CPSC rule | Products designed or intended primarily for children 12 and under |
| Testing basis | A test of each product or a reasonable testing program; any competent lab, including the factory's own | Testing by a third-party lab whose accreditation CPSC has accepted, plus periodic and material-change testing |
| Issued by | Importer (for imports) | Importer (for imports) |
| Examples from India | Painted adult furniture, small rugs and bath mats, adult apparel, dressers | Toys, children's furniture and décor, children's clothing |
Some rules use a label instead of a certificate. Upholstered furniture under 16 CFR 1640 needs a permanent compliance label and no GCC; see TB 117-2013 and 16 CFR 1640. Children's products are covered in detail on the CPSIA children's products page.
CPSC rules that most often apply to goods from India
| Rule | What it requires | Typical Indian products |
|---|---|---|
| 16 CFR 1303, lead in paint | Paint and similar surface coatings must not exceed 0.009% (90 ppm) lead in the dried film. Applies to consumer furniture and children's articles that bear paint. | Painted wooden and iron furniture, painted toys and décor for children |
| 16 CFR 1261, clothing storage units (STURDY Act) | Tip-over stability tests, a warning label and a tip restraint for dressers, chests and wardrobes | Sheesham and mango-wood chests and dressers |
| 16 CFR 1640, upholstered furniture (TB 117-2013) | Smolder resistance of cover, filling and barrier; permanent label | Sofas, armchairs, upholstered dining and accent chairs |
| 16 CFR 1630 and 1631, carpets and rugs (guide) | Surface flammability (pill) test; small rugs that fail may be sold only with a permanent "FLAMMABLE" label | Rugs, durries and bath mats from Panipat and Bhadohi |
| 16 CFR 1610, clothing textiles (guide) | Flammability classes for apparel fabrics | Garments, scarves, stoles |
| 16 CFR 1120, substantial product hazard list | Seasonal and decorative lighting must have minimum wire size, strain relief and overcurrent protection (per UL 588), or it can be refused entry | Plug-in string lights and lighted décor |
Many products, such as unpainted solid-wood tables or plain cushion covers for adults, have no CPSC rule and need no certificate. They are still covered by CPSC's general power to act against a substantial product hazard, and the importer must report one if it learns of it.
What the CPSIA added in 2008
- Certificates for all regulated products. The GCC requirement was extended to products subject to any CPSC-enforced rule, and the CPC was created for children's products.
- Third-party testing for children's products at labs whose accreditation CPSC accepts.
- Lead limits. Lead in paint was cut to 90 ppm from 14 Aug 2009. Total lead in accessible parts of children's products was stepped down to 100 ppm from 14 Aug 2011.
- Phthalates in children's toys and child care articles (now 16 CFR 1307).
- Tracking labels on children's products and their packaging.
- Durable infant and toddler products: mandatory standards, product registration cards and permanent marking (16 CFR 1130).
- Toy safety: ASTM F963 made mandatory (16 CFR 1250).
- A public incident database, SaferProducts.gov, and higher civil penalties.
Certificate eFiling: mandatory since 8 July 2026
CPSC rewrote 16 CFR 1110 in a final rule published on 8 January 2025 (90 FR 1843). From 8 July 2026, importers must eFile the certificate data for regulated products with CBP when they file the entry, through CPSC's message set in ACE or by referencing a certificate stored in CPSC's Product Registry. Goods entered from a Foreign Trade Zone follow from 8 January 2027. CPSC confirmed on 8 July 2026 that the program is in effect and that it creates no new testing or certification duties.
Each certificate must give, among other things:
- A product identifier (GTIN, model number, SKU or similar) and a description that matches the goods.
- Every applicable rule, listed separately, and any testing exclusion relied on.
- The certifier's name and full contact details, and the person who keeps the records.
- The month and year, and the place, of manufacture, with the factory's name, address, email and phone.
- The date and place of the most recent testing, with each lab's details.
For an Indian supplier this means the importer needs accurate factory addresses, production dates and lab report details before the goods ship, not after.
What an inspection can verify, and what needs a lab
| An inspector at the factory can check | Only a lab can establish |
|---|---|
| Model numbers, SKUs and factory details on goods and cartons match the certificate | Lead content of paint and substrates |
| Required labels are present: 16 CFR 1640 label, STURDY warning label, rug "FLAMMABLE" label, tracking labels | Flammability classes of fabrics and rugs |
| Paint, finish, fabric and components match those named in the test reports | STURDY tip-over stability results |
| Test reports are current and cover the products in the shipment | Phthalate content and other chemical limits |
How Clear To Load checks this in India
Tell us which CPSC rules your certificate cites. During a pre-shipment inspection in India the inspector checks labels and markings, compares materials and finishes with your test reports, and records the production date and factory address you need for eFiling. Where you need new tests, we pull and seal samples for an ISO/IEC 17025-accredited lab you choose (CPSC-accepted for children's products) through lab testing coordination.
Each report ends in a verdict, Cleared to load, Hold or Not cleared, and arrives within 24 hours of the inspection. The certificate remains the importer's legal statement. To add these checks to an order, book an inspection.
Sources
- 16 CFR Part 1110, Certificates of Compliance (eCFR)
- CPSC: Update, Certificates of Compliance and eFiling
- CPSC news release, 8 Jul 2026: mandatory eFiling of certificates in effect
- 16 CFR Part 1303, Ban of Lead-Containing Paint (eCFR)
- 16 CFR Part 1631, Small Carpets and Rugs (eCFR)
- CPSC: Seasonal and Decorative Lighting Products rule