CPC or GCC: which certificate your product needs
The dividing line is who the product is for, and it decides who may test it.
Updated 11 October 2026
What the texts say
CPSC lists the children's product safety rules that require third-party testing, with the legal citation to put on a Children's Product Certificate.
Official text
Below is a list of children's product safety rules that require third-party testing as well as the legal citation to be used on a Children's Product Certificate (CPC)
— CPSC, retrieved 11 October 2026Third party testing is required to support a certification of compliance to the rules (shown below) for children's products.
— CPSC, retrieved 11 October 2026
A children's product must be tested by a CPSC-accepted laboratory. There is no equivalent obligation for a general-use product.
Official text
Children's products must be tested by a CPSC-accepted laboratory
— CPSC, retrieved 11 October 2026Any laboratory—an in-house or an external, third party laboratory—can perform the testing required for non-children's products.
— CPSC, retrieved 11 October 2026
A general certificate rests on a test of each product or a reasonable testing program, done by any laboratory, in-house or external.
Official text
The GCC must be based on a test of each product or a reasonable testing program.
— CPSC, retrieved 11 October 2026Any laboratory—an in-house or an external, third party laboratory—can perform the testing required for non-children's products.
— CPSC, retrieved 11 October 2026
For a toy, the certificate must also list the individual sections of the accepted version of ASTM F963 that apply, not just 16 CFR part 1250.
Official text
The CPC must also include the individual sections of the currently accepted version of ASTM F963 applicable to the product and not simply cite 16 CFR part 1250.
— CPSC, retrieved 11 October 2026Children's toys (ASTM F963) [1] 16 CFR part 1250
— CPSC, retrieved 11 October 2026
Adult wearing apparel exempt from testing is treated differently from children's apparel: CPSC says it will not enforce certification for the first, and that the second is not afforded that discretion.
Official text
CPSC will not enforce the certification requirements for adult wearing apparel that is exempt from testing pursuant to 16 CFR § 1610.1(d)
— CPSC, retrieved 11 October 2026Wearing apparel that are considered children's products are not afforded this enforcement discretion.
— CPSC, retrieved 11 October 2026
One question decides it: who is it for
Two certificates exist and they are not two formats of the same thing. A general certificate covers a product meant for everyone; a children's product certificate covers one designed or intended primarily for children twelve or younger. Everything else - the cost, the laboratory, the delay - follows from that single classification.
« Children's product means a consumer product designed or intended primarily for children 12 years of age or younger. »The classification is not a label you choose. It follows from how the product is designed, how it is decorated, how it is advertised and where it is sold, which is why the same object can be a children's product in one shop and not in another.
The practical test is not what you intend but what a reader would conclude from your listing. A shop that writes the same product two ways - a keepsake for adults in one place, a first toy in another - has written two different classifications, and only one of them matches what the certificate says.
Who is allowed to test
This is where the two regimes separate in your budget. For a product that is not for children, the testing behind the certificate may come from any laboratory - including the manufacturer's own bench.
« Any laboratory—an in-house or an external, third party laboratory—can perform the testing required for non-children's products. »For a children's product there is no such latitude: the laboratory has to be one CPSC has accepted, and its name, address and test date go on the certificate. That is the single line that turns a two-day task into a four-week one.
« Children's products must be tested by a CPSC-accepted laboratory »What each one has to say
Both certificates name the rules the product is certified to, separately rather than in a bundle. A CPC goes further for some standards: for toys it must cite the individual sections of the standard that apply, not the part number alone.
« The CPC must also include the individual sections of the currently accepted version of ASTM F963 applicable to the product and not simply cite 16 CFR part 1250. »CPSC's list of rules requiring third-party testing is the reference for all of this, and it carries its own date - a reminder that these lists move and that a certificate written two years ago may cite something that has since changed.
« This list is complete as of December 5, 2024. »Is your product concerned?
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Frequently asked questions
Which rules does a toy fall under?
CPSC's list names children's toys under 16 CFR part 1250, total lead content under 15 U.S.C. § 1278a, lead paint under part 1303, phthalates under part 1307 and small parts under part 1501. Which of them apply to your toy is the certifier's judgement.
I make very small quantities. Does that change the testing?
CPSC writes that qualifying and registered small batch manufacturers may be able to receive relief from third-party testing for certain rules. Registration with CPSC is what opens that door.
How current is CPSC's list?
The children's product list carries its own date: CPSC states it is complete as of 5 December 2024. We re-read the page every day and date every quotation on this site.
Sources
- CPSC, Rules Requiring Third Party Testing (Children's Product Certificate) · retrieved 11 October 2026
- CPSC, General Use Products Certification and Testing · retrieved 11 October 2026
- CPSC, Rules Requiring a General Certificate of Conformity · retrieved 11 October 2026
- eCFR, 16 CFR 1200.2 · retrieved 24 August 2026