Is a laboratory test report a certificate of compliance?

No. Under 16 CFR 1110.3 the certifier means the party who issues a certificate of compliance, and a finished product certifier must be an importer, a manufacturer or a private labeler - not a laboratory. The laboratory is identified on the certificate under 16 CFR 1110.11(a)(6). A test report also carries none of the seven required content elements as such, and no certifier's attestation.

Can I give my customs broker a test report instead of certificate data?

What 16 CFR 1110.13(a)(1) requires to be eFiled into CBP's ACE at entry is the certificate data elements. A test report is not that data set, though the facts a broker files - test date, testing laboratory - come from the testing the certificate rests on.

Does having a certificate replace testing?

No. CPSC states that certification is based on test results - from a CPSC-accepted third-party laboratory for a children's product - and 16 CFR 1110.11(a)(6) requires the certificate to identify the most recent test date and each testing body on whose testing it depends. The certificate restates what the testing established; it does not stand in for it.

A test report is not a certificate of compliance

Different authors

The two documents are separated by who writes them. In § 1110.3’s words: “Certifier means the party who issues a certificate of compliance.” And “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)).” A laboratory is none of those parties.

The rule gives the laboratory a different place: it appears on the certificate. Paragraph (a)(6) requires — quoting the regulation — the date and place of testing, with a full contact block for each testing body the certificate depends on.

What the certificate carries that a report does not

16 CFR 1110.11(a) sets seven content requirements for a finished product certificate. A test report is not written to carry them:

Product identification 1110.11(a)(1)
Rules certified to 1110.11(a)(2)
Finished product certifier 1110.11(a)(3)
Individual maintaining records 1110.11(a)(4)
Date and place of manufacture 1110.11(a)(5)
Date and place of testing 1110.11(a)(6)
Certifier's attestation 1110.11(a)(7)

The last of the seven decides the question by itself. The attestation of (a)(7) is made by the finished product certifier in prescribed wording — quoted in full here — and only the certifier can sign it. A laboratory’s report, however thorough, cannot contain another party’s attestation.

Where the report fits

The report is not waste paper — it is what the certificate rests on. CPSC states that certification is based on test results, from a CPSC-accepted third-party laboratory for a children’s product, and the certificate identifies the most recent test date and each testing body it depends on under (a)(6).

Questions

Is a laboratory test report a certificate of compliance?: No. Under 16 CFR 1110.3 the certifier means the party who issues a certificate of compliance, and a finished product certifier must be an importer, a manufacturer or a private labeler - not a laboratory. The laboratory is identified on the certificate under 16 CFR 1110.11(a)(6). A test report also carries none of the seven required content elements as such, and no certifier's attestation.
Can I give my customs broker a test report instead of certificate data?: What 16 CFR 1110.13(a)(1) requires to be eFiled into CBP's ACE at entry is the certificate data elements. A test report is not that data set, though the facts a broker files - test date, testing laboratory - come from the testing the certificate rests on.
Does having a certificate replace testing?: No. CPSC states that certification is based on test results - from a CPSC-accepted third-party laboratory for a children's product - and 16 CFR 1110.11(a)(6) requires the certificate to identify the most recent test date and each testing body on whose testing it depends. The certificate restates what the testing established; it does not stand in for it.

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The quoted definitions on this page come from 16 CFR part 1110 as published by the eCFR, retrieved 2026-08-24; the seven content requirements are quoted on their own pages. CertSeven gives no legal advice and does no testing.