Who certifies, quoted

16 CFR 1110.7(a), QUOTED
Except as otherwise provided in a specific rule, ban, standard, or regulation enforced by CPSC, for a finished product manufactured outside of the United States that must be accompanied by a certificate as set forth in § 1110.5, the importer, as defined in this part, is the finished product certifier that must issue a finished product certificate that meets the requirements of this part.

“Importer” has a precise meaning here. Under § 1110.3, “Importer, for the purposes of this part, means the Importer of Record (IOR) eligible to make entry for imported finished products under the Tariff Act of 1930, as amended (19 U.S.C. 1484(a)(2)(B)), who may be an owner, purchaser, or authorized customs broker” — the party eligible to make entry, not the overseas factory. If you import to sell, that party is you.

Certifying your own product

The instinctive objection — a certificate I write about myself is worth nothing— deserves a direct answer:

Wait — I certify my own product?

Yes — and not doing so is what is not allowed. CPSC states that section 14 of the CPSA, codified in 16 CFR part 1110, requires importers to certify in writing, based on test results. No authority issues one for you.

You restate facts, you do not vouch for your own product. A supplier’s certificate can give you the facts, never its signature. Never write one you do not have.

What each of the seven paragraphs asks for · What your broker needs

What their paper is for

Paragraphs (a)(5) and (a)(6) of 16 CFR 1110.11 ask for facts that live with your supply chain — where and when the product was made, who tested it and how to reach them. The factory’s certificate or its test report is usually where those facts are written down. So the sequence is:

  1. Check what they sent — see which of the seven elements it gives you, free.
  2. Ask for what is missing — one click writes the request, in English and 中文, citing each gap.
  3. Issue the certificate in your own name — their facts, your signature.

Questions

Can I use the certificate my supplier sent me?
As the source of facts, yes - it is usually where the manufacture and testing details live. As the certificate, no: 16 CFR 1110.7 provides that for a finished product manufactured outside the United States the importer is the finished product certifier that must issue the certificate. The factory's document does not become yours by being forwarded.
Does the factory's certificate transfer the responsibility?
No. Under 16 CFR 1110.15 the finished product certifier remains legally responsible for the information in the certificate, including its validity, accuracy, completeness and availability - whoever supplied the underlying facts.
My supplier will not share a detail. Can I fill in what seems right?
No. 16 CFR 1110.11(a)(7) has the certifier attest to the certificate in prescribed wording which acknowledges that a knowingly false statement is a federal offence. A fact you do not have has to come from the party who holds it. The checker writes that request for you, in English and Chinese, listing exactly what is missing with its citation.

Start with what your supplier sent

Paste it and see, requirement by requirement, which facts you already hold and which to ask for. Free, in your browser; nothing is uploaded.

Check their certificate

The quotations on this page come from 16 CFR part 1110 as published by the eCFR, retrieved 2026-08-24. CertSeven gives no legal advice. Under 16 CFR 1110.15 the finished product certifier remains legally responsible for the information in the certificate.