Is a certificate written before 8 July 2026 still valid?

A certificate written to the superseded requirements is missing facts the current rule asks for, typically the certifier's email address and the attestation. Whether a given certificate satisfies the rule is a judgement for the finished product certifier, who remains legally responsible for it under 16 CFR 1110.15.

Why does so much guidance still cite paragraphs (e), (f) and (g)?

Those paragraph letters were the content requirements under the superseded text. The letters (b), (c) and (d) were reused for entirely different subject matter and (e) through (g) are gone, so guidance written before July 2026 points at paragraphs that either do not exist or now mean something else.

Who has to certify an imported product?

Under 16 CFR 1110.7, for a finished product manufactured outside the United States the importer is the finished product certifier, not the foreign factory. A certificate the factory supplies does not transfer that obligation.

What changed in 16 CFR 1110.11 on 8 July 2026

The paragraphs moved

The section was renamed from “Content of certificate” to “Certificate content”. The seven content requirements are now designated as follows — each links to its full quoted text — and the letters (b), (c) and (d) were reused for entirely different subject matter.

Paragraph	What it requires
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

What got stricter, and what is new

The certifier now needs an email address 1110.11(a)(3)

Paragraph (a)(3) asks for the finished product certifier's name, street address, city, state or province, country or administrative region, email address and telephone number. The superseded text did not ask for an email address, so a certificate written to the old requirements is short of this one no matter how carefully it was prepared.

Manufacture and testing need full contact blocks 1110.11(a)(5) and (a)(6)

A city and a country no longer satisfy the place of manufacture. Paragraph (a)(5) requires the manufacturer's name, street address, city, state or province, country or administrative region, email address and telephone number, and a date to at least month and year. Paragraph (a)(6) asks for the most recent test date and the same detail for each testing body the certificate depends on.

There is a seventh requirement that did not exist before 1110.11(a)(7)

Paragraph (a)(7) requires an attestation. For a paper or electronic certificate the rule prescribes the words, so a summary in other words is not that attestation. A certificate written before 8 July 2026 has no attestation at all, which is why a pre-July template fails at least two requirements outright.

The attestation, in full

This is the wording 16 CFR 1110.11(a)(7) sets out for a paper or electronic certificate, quoted from the regulation.

The prescribed wording

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.

Questions

What changed in 16 CFR 1110.11 on 8 July 2026?: The section was renamed from Content of certificate to Certificate content and restructured. 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 rather than a city and country, and a seventh requirement was added: an attestation in wording the rule prescribes.
Is a certificate written before 8 July 2026 still valid?: A certificate written to the superseded requirements is missing facts the current rule asks for, typically the certifier's email address and the attestation. Whether a given certificate satisfies the rule is a judgement for the finished product certifier, who remains legally responsible for it under 16 CFR 1110.15.
Why does so much guidance still cite paragraphs (e), (f) and (g)?: Those paragraph letters were the content requirements under the superseded text. The letters (b), (c) and (d) were reused for entirely different subject matter and (e) through (g) are gone, so guidance written before July 2026 points at paragraphs that either do not exist or now mean something else.
Who has to certify an imported product?: Under 16 CFR 1110.7, for a finished product manufactured outside the United States the importer is the finished product certifier, not the foreign factory. A certificate the factory supplies does not transfer that obligation.

Check a certificate against the current text

Paste the certificate your supplier sent. It reports, requirement by requirement, what is present and what is missing, and resolves every cited rule against the title 16 inventory. Free, and it runs entirely in your browser.

Check a certificate

Every statement on this page traces to the text of 16 CFR part 1110 as published by the eCFR. Part 1110 was last amended 2026-07-08; this page was last verified against the eCFR on 2026-10-01. Read the regulation.