When a certificate is turned down, the document itself usually fails one of three paragraphs of 16 CFR 1110.11(a): (a)(1), which now requires a unique product identifier and not merely a description; (a)(2), which requires every applicable rule to be identified separately rather than covered by blanket wording; and (a)(6), which requires the name, street address, city, state or province, country or administrative region, email address and telephone number of each testing body the certificate depends on. 16 CFR 1110.13(a) separately requires each finished product certificate to describe only one product.

Whose requirements you are being held to

This matters practically, not just legally. A document can satisfy 16 CFR 1110.11(a) completely and still be turned down by a buyer who wants something extra, and it can be accepted by a buyer while still failing the rule. Only one of those two is a federal obligation, and it is the one that survives an entry review.

The three failures

The product is not identified uniquely

16 CFR 1110.11(a)(1)

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.

Shape the rule asks for

Wooden stacking rings, natural beech — SKU WSR-114

Falls short

Wooden toys

There is no unique identifier and the description is too broad to match a specific finished product to the certificate.

One certificate, one finished product, and an identifier that ties them together. Read the paragraph in full.

The rules are not named separately

16 CFR 1110.11(a)(2)

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.

Shape the rule asks for

16 CFR Part 1250 (Safety Standard for Toys); 16 CFR Part 1303 (Ban of Lead-Containing Paint); 15 U.S.C. 1278a (lead content limits)

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.

Each applicable rule stated on its own line, not gathered under one phrase. Read the paragraph in full.

The testing body is not fully named

16 CFR 1110.11(a)(6)

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.

Shape the rule asks for

12 April 2026 — Wellsure Testing Services Ltd, 4F Block C, 128 Keyuan Road, Nanshan, Shenzhen, Guangdong, China — reports@wellsure-testing.cn — +86 755 8899 6120

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.

Seven contact facts for each laboratory the certificate depends on. Read the paragraph in full.

These constructions illustrate the shape the regulation asks for. They are not observed documents, and CertSeven publishes no figures on how often real certificates fail a given paragraph, because it has no sourced data on frequency.

What to do now

Check the document you already have before rewriting anything: the fault is often one field rather than the whole certificate. The free checker reports which of the seven content requirements are present and whether every rule it cites resolves against the complete title 16 inventory. It runs entirely in your browser — the certificate is never sent anywhere, which you can confirm in your own network panel.

If the product itself is the question rather than the document, the rules that name what you sell are listed by product.

Questions

Why would a certificate be rejected when the product was tested?
Testing and certifying are different acts. A test report is evidence; the certificate is the document 16 CFR 1110.11(a) prescribes, and it has seven content requirements that a laboratory report does not carry. A product can be tested properly and still have a certificate that omits the certifier's email address, names no rule separately, or carries no unique product identifier.
Does one certificate cover a whole product range?
No. 16 CFR 1110.13(a) requires each finished product certificate to describe only one finished product. A single document written to cover a range does not meet the rule, which is also why 1110.11(a)(1) asks for a unique identifier - a GTIN, model number, registered number, serial number, SKU, UPC or alternate identifier - alongside a description sufficient to match the product to the certificate.
Is "complies with all applicable CPSIA requirements" enough?
No. 16 CFR 1110.11(a)(2) requires each applicable rule, ban, standard or regulation to be identified separately. A statement that everything is complied with identifies no rule at all, so nothing has been stated separately. These are also the data elements eFiled into ACE at entry.
What does the certificate have to say about the laboratory?
For a children's product, 16 CFR 1110.11(a)(6) requires the name, street address, city, state or province, country or administrative region, email address and telephone number of each third party conformity assessment body on whose testing the certificate depends. Acceptance is granted per rule under 16 CFR part 1112, so a laboratory accepted for one standard is not automatically accepted for another.

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