Is your certificate of compliance still valid?

16 CFR 1110.11(a) sets out seven content requirements: product identification, the rules certified to, the finished product certifier, the individual maintaining test records, the date and place of manufacture, the date and place of testing, and the certifier's attestation. Each contact block needs a name, street address, city, state or province, country or administrative region, email address and telephone number.

16 CFR 1110.11 was renamed and restructured effective 8 July 2026. The content requirements moved from paragraphs (a) through (g) to (a)(1) through (a)(7). The certifier now needs an email address, the places of manufacture and testing need full contact blocks, and a seventh requirement was added: an attestation in wording the rule prescribes.

It depends on whether the transaction is commercial. CPSC states that eFiling is not required for noncommercial transactions, meaning a product sent outside a commercial transaction such as a gift or a transfer of personal effects. Anything you intend to sell is commercial, including one consumer selling to another through an online marketplace, and is not covered by that exemption.

You do, if you are the importer. CPSC states that section 14 of the CPSA, codified in 16 CFR part 1110, requires domestic manufacturers and importers to certify in a written certificate, based on test results - from a CPSC-accepted third-party laboratory for a children's product. Nobody counter-signs it. Its weight comes from the attestation 16 CFR 1110.11(a)(7) requires, because a knowingly false certificate is a federal offence.

Under 16 CFR 1110.7, for a finished product manufactured outside the United States the importer is the finished product certifier. A certificate supplied by the foreign factory does not move that obligation, and under 16 CFR 1110.15 the certifier remains legally responsible for the information in the certificate.

For goods manufactured outside the United States and offered for importation, 16 CFR 1110.13(a)(1) requires the certificate data elements to be eFiled into CBP's ACE at the time the entry is filed. That filing is done by the importer or their customs broker. Hosting a certificate at a verifiable address addresses the separate furnishing and availability duties in 16 CFR 1110.13(b) and (c).

CertSeven checks a pasted certificate against all seven content requirements of 16 CFR 1110.11(a) and resolves every rule it cites against the current title 16 inventory, free and without an account. The check runs entirely in the browser, so the certificate is not uploaded anywhere.