GCC vs CPC: which certificate does your product need?

Two types, defined by the rule

The restructured part 1110 defines both terms itself, in § 1110.3. This is the whole distinction, in the regulation’s words:

So the CPC is the children’s product route — section 14(a)(2) and part 1107 are the children’s product testing provisions — and the GCC, the only other type, is the certificate for everything else.

Which one is yours

The question reduces to whether the product is a children’s product:

If it is, the certificate is a CPC and rests on third-party testing. In § 1110.3’s words: “Third party conformity assessment body means a testing laboratory whose accreditation has been accepted by the CPSC to conduct certification testing on children's products, as required in § 1107.2 of this chapter.” If it is not, the certificate is a GCC.

Whether a given product falls on one side or the other is determined by statutory factors elaborated in 16 CFR part 1200, and it is the certifier’s determination to make. The rules inventory marks each children’s product rule on its page.

The content is the same seven requirements

Both are finished product certificates, and 16 CFR 1110.11(a) sets the content of a finished product certificate: the seven elements from product identification through the certifier’s attestation. What differs between a GCC and a CPC is what sits underneath the certificate — the rules cited under (a)(2) and the testing identified under (a)(6) — not what has to appear on it.

Who issues either one

Under § 1110.3, “a finished product certifier must be an importer, as defined in this section, or a manufacturer or private labeler as defined in sections 3(a)(11) and (12) of the CPSA (15 U.S.C. 2052(a)(11) and (12)).” For a finished product manufactured outside the United States, 16 CFR 1110.7 makes the importer the finished product certifier — not the factory, and not the laboratory. Why the supplier’s certificate is not yours.

Questions

What is the difference between a GCC and a CPC?

Both are finished product certificates under 16 CFR 1110.3, which recognises exactly two types. A Children's Product Certificate is issued pursuant to section 14(a)(2) of the CPSA and part 1107 - the children's product route, which rests on testing by a third-party laboratory whose accreditation CPSC has accepted. A General Certificate of Conformity is issued pursuant to section 14(a)(1) and is the type for a finished product that is not a children's product. The content requirements are the same seven either way.

What counts as a children's product?

16 CFR 1200.2 defines a children's product as a consumer product designed or intended primarily for children 12 years of age or younger, determined by considering four statutory factors set out in the CPSA and elaborated in part 1200.

Does a Children's Product Certificate require third-party testing?

16 CFR 1110.3 defines the third party conformity assessment body as a testing laboratory whose accreditation has been accepted by CPSC to conduct certification testing on children's products, as required in section 1107.2. Acceptance is granted per rule under 16 CFR part 1112, so a laboratory accepted for one standard is not automatically accepted for another.

Do a GCC and a CPC have different content requirements?

No. Both are finished product certificates, and the content requirements of 16 CFR 1110.11(a) - the seven elements, from product identification through the certifier's attestation - apply to finished product certificates as such. What differs is what sits underneath: the rules cited under (a)(2) and the testing identified under (a)(6).