# CPC or GCC: which certificate does my product need?

> A Children's Product Certificate (CPC) is for products designed primarily for children 12 and under and needs third-party testing. A General Certificate of Conformity (GCC) is for regulated general-use products. How to tell, with CPSC's own citation codes.

Checked against sources: 22 September 2026 · https://complygoods.com/guides/cpc-vs-gcc/

## Quick answer

A Children's Product Certificate (CPC) is required for a children's product (one designed or intended primarily for children 12 or younger) that is subject to a children's product safety rule, and it must be based on testing by a CPSC-accepted third-party laboratory. A General Certificate of Conformity (GCC) is required for a regulated general-use product and can rest on a reasonable testing programme. Both are issued by the importer for imported products, and both now go into eFiling.


## The difference in one table

|  | CPC | GCC |

| Product | Children's product (designed primarily for 12 and under) | General-use product subject to a CPSC rule |

| Testing basis | Third-party testing by a CPSC-accepted lab | A test of each product or a reasonable testing programme |

| Who issues it (imports) | The importer | The importer |

| Records kept | 5 years | 5 years (extended from 3 by the 2025 rule) |

| eFiled since 8 July 2026 | Yes | Yes |

## How CPSC's own code list splits them

CPSC's eFiling citation code list (December 2025) marks each rule as CPC, GCC or both. Of its 130 citation codes, 83 are CPC-only, 26 GCC-only and 14 apply to both, such as bicycle helmets (1203), bicycles (1512), mattresses (1632, 1633) and button cell batteries (1263.3). The full list is in the [citation codes dataset](https://complygoods.com/data/citation-codes/), and the rules by product type in [product requirements](https://complygoods.com/data/product-requirements/).</p>

## Can my factory, my lab or my broker issue it?

For imported finished products, the importer is the certifier. Since 2011, 16 CFR part 1109 lets the importer rely on a supplier's or manufacturer's testing and certification when it issues its own certificate, with due care. A lab issues test reports, not the importer's certificate. A broker transmits the data. In the Product Registry the importer's administrator can let other users certify, but CPSC is clear that "the certification process is ultimately the responsibility of the importer."</p>

## When no certificate is needed

Some products are within CPSC's reach but need no certificate: products under no rule that requires one, and a few where CPSC uses enforcement discretion, such as adult apparel exempt under 16 CFR 1610.1(d). Those entries use a Disclaim message instead. See [Disclaim A or Disclaim B](https://complygoods.com/guides/cpsc-disclaim-a-vs-disclaim-b/).</p>


## Sources

- CPSC: Children's Product Certificate FAQ: <https://www.cpsc.gov/FAQ/CPC>
- CPSC: General Certificate of Conformity: <https://www.cpsc.gov/Business--Manufacturing/Testing-Certification/General-Certificate-of-Conformity>
- CPSC: eFiling Citation and Testing Exception Codes (Excel, Dec 2025): <https://www.cpsc.gov/s3fs-public/2025-12-18_eFiling-Citation-and-Testing-Exception-Codes.xlsx>
- CPSC: Third-party testing guidance: <https://www.cpsc.gov/Business--Manufacturing/Testing-Certification/Third-Party-Testing>
- eCFR: 16 CFR Part 1110: <https://www.ecfr.gov/current/title-16/part-1110>
- eCFR: 16 CFR Part 1107: <https://www.ecfr.gov/current/title-16/part-1107>
- CPSC: Product Registry FAQ V1.4 (PDF): <https://www.cpsc.gov/s3fs-public/Product_Registry_Frequently_Asked_Questions_V1-4.pdf>

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