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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

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

CPCGCC
ProductChildren's product (designed primarily for 12 and under)General-use product subject to a CPSC rule
Testing basisThird-party testing by a CPSC-accepted labA test of each product or a reasonable testing programme
Who issues it (imports)The importerThe importer
Records kept5 years5 years (extended from 3 by the 2025 rule)
eFiled since 8 July 2026YesYes

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, and the rules by product type in product requirements.

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."

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.

Sources

Primary sources first; provider pages only for their own prices.

Razvan Toma
Researched and maintained byRazvan Toma

Founder of ComplyGoods. Publishes open data on product-compliance regimes (also eprfrancerep.com and eprgermanyrep.com). Every figure here links to the government file or provider page it was read from.

Razvan Toma on LinkedIn ↗

Importing consumer products into the US?

Certificate data is now filed with every entry. Check which CPSC rules your product falls under, then keep every product's certificate data complete, current and provable.