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16 CFR 1110.11(a) sets out seven content requirements, and a finished product certificate has to carry all of them: the product identification, the rules certified to, the finished product certifier, the individual maintaining records, the date and place of manufacture, the date and place of testing, and the certifier's attestation. Two of them changed on 8 July 2026 - an email address is now required for the certifier, and a unique product identifier is mandatory rather than good practice.

The seven, field by field

1. 1Product identification

   16 CFR 1110.11(a)(1)
   • At least one unique identifier: GTIN, model number, registered number, serial number, SKU, UPC or alternate identifier
   • A sufficient description to match the product to the certificate

   A unique identifier is now mandatory rather than good practice, and a description alone does not satisfy the paragraph. Note also that 16 CFR 1110.13(a) requires each finished product certificate to describe only one product.

   Falls short
   “Wooden toys” — There is no unique identifier and the description is too broad to match a specific finished product to the certificate.

2. 2Rules certified to

   16 CFR 1110.11(a)(2)
   • Every applicable rule, ban, standard or regulation, identified separately

   The paragraph asks for each applicable rule to be identified separately. Blanket wording such as complies with all applicable CPSIA requirements identifies nothing, and a citation to a part that does not exist cannot be a citation to a rule the product is certified to. These are the same data elements that get eFiled into ACE at entry.

   Falls short
   “Complies with all applicable CPSIA requirements” — A statement that everything is complied with identifies no rule at all, so nothing has been stated separately.

3. 3Finished product certifier

   16 CFR 1110.11(a)(3)
   • Name
   • Street address
   • City
   • State or province
   • Country or administrative region
   • Email address
   • Telephone number

   An email address is now required here, which it was not before 8 July 2026. Under 16 CFR 1110.7 the certifier is the importer for goods manufactured outside the United States, the manufacturer for domestic goods, and the private labeler for domestic privately labelled goods unless the manufacturer issues the certificate.

   Falls short
   “Ningbo Brightstar Toys Co., Ltd, Ningbo, China” — For imported goods 16 CFR 1110.7 makes the importer the finished product certifier, and the entry has no email address in any case.

4. 4Individual maintaining records

   16 CFR 1110.11(a)(4)
   • Individual's name, or a position title that is always staffed
   • Street address
   • City
   • State or province
   • Country or administrative region
   • Email address
   • Telephone number

   A position title is explicitly allowed, provided the position is always staffed and responsive to CPSC's requests. The records in question are the ones 16 CFR 1110.17 requires to be kept for at least five years from the certificate creation date.

   Falls short
   “compliance@northgateimports.com” — An email address on its own gives neither an individual nor a staffed position title, and none of the address or telephone details the paragraph asks for.

5. 5Date and place of manufacture

   16 CFR 1110.11(a)(5)
   • Date, month and year at a minimum
   • Manufacturer name
   • Street address
   • City
   • State or province
   • Country or administrative region
   • Email address
   • Telephone number

   The place is now a full contact block for the manufacturer, not a city and country. For a run spanning several days, the initial date of manufacture is the one to give.

   Falls short
   “2026 — China” — Month and year is the stated minimum for the date, and the place has to carry the manufacturer's name, street address, email and telephone number as well as the city and region.

6. 6Date and place of testing

   16 CFR 1110.11(a)(6)
   • The most recent test date
   • For each testing body: name
   • Street address
   • City
   • State or province
   • Country or administrative region
   • Email address
   • Telephone number

   The date required is the most recent one, not the date of any earlier test. Each third party conformity assessment body the certificate depends on needs a full contact block. Where a statutory or regulatory testing exclusion is claimed, 16 CFR 1110.11(c) puts the identification of that exclusion in place of the testing date and place for that rule.

   Falls short
   “Tested by Wellsure” — No date is given, and the testing body is named without the address, email and telephone number the paragraph asks for.

7. 7Certifier's attestation

   16 CFR 1110.11(a)(7)
   • The attestation, in the wording the paragraph sets out

   This requirement did not exist before 8 July 2026. For an eFiled certificate the attestation is carried by the Product Registry and the CATAIR message set. For a paper or electronic certificate the rule prescribes the words, so they have to appear as written rather than paraphrased.

   Falls short
   “We confirm the above is correct.” — The paragraph sets out the wording, including the acknowledgement that a knowing false statement on the certificate is a federal crime. A summary in other words is not that attestation.

These constructions illustrate the shape the regulation asks for. They are not observed documents, and no claim is made here about how often real certificates fail a given paragraph.

What changed on 8 July 2026

Two of the seven moved, and both are easy to miss on a document copied from an older template: an email address is now required for the certifier under 1110.11(a)(3), and a unique product identifier is mandatory under 1110.11(a)(1) rather than merely good practice. The old (a) to (g) lettering is gone; paragraphs are cited as (a)(1) through (a)(7). The full comparison is on what changed on 8 July 2026.

Questions

How many things must a certificate contain?

Seven, under 16 CFR 1110.11(a): 1110.11(a)(1) product identification; 1110.11(a)(2) rules certified to; 1110.11(a)(3) finished product certifier; 1110.11(a)(4) individual maintaining records; 1110.11(a)(5) date and place of manufacture; 1110.11(a)(6) date and place of testing; 1110.11(a)(7) certifier's attestation. The same seven apply whether the document is a Children's Product Certificate or a General Certificate of Conformity.

Is a product description enough to identify the product?

No. 16 CFR 1110.11(a)(1) requires at least one unique identifier - a global trade item number, model number, registered number, serial number, stock keeping number, universal product code or alternate identifier - along with a description sufficient to match the finished product to the certificate. A description on its own does not satisfy the paragraph.

Does the certificate need an email address?

Yes, and this is one of the changes of 8 July 2026. 16 CFR 1110.11(a)(3) requires the finished product certifier's name, street address, city, state or province, country or administrative region, email address and telephone number. 1110.11(a)(6) requires the same seven facts for each testing body the certificate depends on.

Can the attestation be written in my own words?

16 CFR 1110.11(a)(7) prescribes the wording. It reads: “I hereby certify that the finished product(s) covered by this certificate comply with the rules, bans, standards, and regulations stated herein, and that the information in this certificate is true and accurate to the best of my knowledge, information, and belief. I understand and acknowledge that it is a United States federal crime to knowingly and willfully make any materially false, fictitious, or fraudulent statement, representation, or omission on this certificate.”