The seven content requirements of 16 CFR 1110.11(a)

A certificate of compliance is not a free-form letter. 16 CFR 1110.11(a) sets out seven things a finished product certificate must contain. The text below is quoted from the regulation rather than paraphrased.

1. 1110.11(a)(1)Product identification

   Identify the finished product(s) covered by the certificate. Finished product certificates must contain at least one of the following unique identifiers: global trade item number (GTIN), model number, registered number, serial number, stock keeping number (SKU), universal product code (UPC), or alternate identifier, along with a sufficient description to match the finished product to the certificate. Finished product certificates may also include other identifiers, such as lot number, model style, and model color, that may assist with product identification.

   What has to be present

   • 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

   What the paragraph requires: 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.

   Worked examples for this requirement

2. 1110.11(a)(2)Rules certified to

   State each consumer product safety rule under the CPSA, or similar rule, ban, standard, or regulation under any law enforced by the Commission, to which the finished product(s) are being certified. Finished product certificates must identify separately all applicable rules, bans, standards, or regulations.

   What has to be present

   • Every applicable rule, ban, standard or regulation, identified separately

   What the paragraph requires: 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.

   Worked examples for this requirement

3. 1110.11(a)(3)Finished product certifier

   Identify the finished product certifier that is certifying compliance of the finished product(s), as set forth in § 1110.7, including the party's name, street address, city, state or province, country or administrative region, electronic mail (email) address, and telephone number.

   What has to be present

   • Name
   • Street address
   • City
   • State or province
   • Country or administrative region
   • Email address
   • Telephone number

   What the paragraph requires: 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.

   Worked examples for this requirement

4. 1110.11(a)(4)Individual maintaining records

   Identify and provide contact information (consisting, at a minimum, of the individual's name, street address, city, state or province, country or administrative region, email address, and telephone number) for the individual maintaining records listed in § 1110.17 on behalf of the finished product certifier. The individual can be a position title, provided that the position is always staffed and responsive to CPSC's requests.

   What has to be present

   • 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

   What the paragraph requires: 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.

   Worked examples for this requirement

5. 1110.11(a)(5)Date and place of manufacture

   Provide the date (month and year, at a minimum) and place (including a manufacturer name, street address, city, state or province, country or administrative region, email address, and telephone number) where the finished product(s) were manufactured, produced, or assembled. For manufacturing runs over a series of days, provide the initial date of manufacture (month and year, at a minimum).

   What has to be present

   • Date, month and year at a minimum
   • Manufacturer name
   • Street address
   • City
   • State or province
   • Country or administrative region
   • Email address
   • Telephone number

   What the paragraph requires: 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.

   Worked examples for this requirement

6. 1110.11(a)(6)Date and place of testing

   Provide the most recent date and place(s) (including for each third party conformity assessment body or other party on whose testing the finished product certificate depends, the name, street address, city, state or province, country or administrative region, email address, and telephone number) where the finished product(s) were tested for compliance with the rule(s), ban(s), standard(s), or regulation(s) cited in § 1110.11(a)(4).

   What has to be present

   • The most recent test date
   • For each testing body: name
   • Street address
   • City
   • State or province
   • Country or administrative region
   • Email address
   • Telephone number

   What the paragraph requires: 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.

   Worked examples for this requirement

7. 1110.11(a)(7)Certifier's attestation

   Provide the finished product certifier's attestation. For eFiled certificates required in § 1110.13(a)(1), attestations are included in the Product Registry and in CPSC's Partner Government Agency (PGA) Message Set CBP and Trade Automated Interface Requirements (CATAIR) Implementation Guide (including revisions thereto). Paper and electronic finished product certificates described in § 1110.9(b) and (c), and required in §§ 1110.13(a)(2), (b), and (c), must include the following attestation by the finished product certifier: 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.

   What has to be present

   • The attestation, in the wording the paragraph sets out

   What the paragraph requires: 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.

   Worked examples for this requirement