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A certificate written to the superseded requirements is missing facts the current rule asks for, typically the certifier's email address and the attestation.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Those paragraph letters were the content requirements under the superseded text.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.

16 CFR 1110.11 · amended 2026-07-08

What changed in 16 CFR 1110.11 on 8 July 2026

Effective 8 July 2026, 16 CFR 1110.11 was renamed and restructured. The content requirements moved from paragraphs (a) through (g) to (a)(1) through (a)(7). Three requirements got stricter and a seventh was added: an attestation in wording the rule prescribes. Guidance citing (e), (f) or (g) describes law that no longer exists.

The paragraphs moved

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

Paragraph	What it requires
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.
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.
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.
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.
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).
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).
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 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.

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.

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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 2026-08-24. Read the regulation.