CPC vs GCC — which certificate does my product need?

Is the product designed or intended primarily for children 12 or younger? If yes, and it is subject to a children's product safety rule, it needs a CPC. If it is a general-use product subject to a consumer product safety rule, it needs a GCC. Some products need neither, if no CPSC rule reaches them.

Both certificates answer the same underlying question — does this product meet the CPSC rules that reach it — for two different kinds of product, and they line up on a few points.

Who it is for: a CPC covers a children's product, one designed or intended primarily for children 12 or younger; a GCC covers a general-use, non-children's product. The rules named: each certificate lists the specific CPSC safety rule or rules the product is certified to. The testing bar: a CPC has to rest on testing by a CPSC-accepted third-party laboratory, while a GCC can rest on testing or a reasonable testing program without an accepted lab. Who issues it: for overseas-made goods the importer issues either certificate, and for domestic goods the U.S. manufacturer does — and that party is legally responsible for it.

A CPC must rest on testing by a CPSC-accepted third-party lab. A GCC can rest on testing or a reasonable testing program, without an accepted third-party lab. So the certificate type is not just a label — it sets a different testing bar.

A CPC is a written certificate for a children's product, stating — based on testing by a CPSC-accepted third-party laboratory — that the product meets the children's safety rules that apply to it. People search for a "CPC template," but there is no official form and nothing to buy: a CPC is a document the importer or manufacturer creates, and what makes it valid is the information on it, not its layout.

The requirement traces to Section 14 of the Consumer Product Safety Act, codified in 16 CFR part 1110, under which seven elements have to be present and accurate. The three checked most often are a description of the exact product the certificate covers, each children's product safety rule it is certified to, and the CPSC-accepted laboratory whose testing it rests on.

A GCC is a written certificate for a general-use product, stating — based on testing or a reasonable testing program — that the product meets each consumer product safety rule that applies to it. As with a CPC, there is no official form to buy; what makes it valid is the information on it. It names each applicable rule, identifies the product it covers, and records the testing the certification rests on.

Unlike a children's product, a general-use product does not need testing by a CPSC-accepted third-party lab — first-party testing, or a lab that is not CPSC-accepted, can support a GCC.

Both certificates trace to Section 14 of the Consumer Product Safety Act and the Consumer Product Safety Improvement Act (CPSIA), carried out through 16 CFR part 1110, so they are often searched with the law's name attached: a "CPSIA general conformity certificate" is the GCC, and a "CPSIA certificate" for a children's product is the CPC. The agency's name gets attached the same way. None of these are separate documents.

Either way, the importer issues the certificate for overseas-made products and the U.S. manufacturer issues it for domestic ones, and that party is legally responsible for it. Both name each applicable safety rule and certify that the product complies.

Some products need neither certificate. A CPC or GCC is only required where a CPSC safety rule actually reaches the product, so a general-use item that no consumer product safety rule covers may need no CPSC certificate at all. That is a real outcome, not a gap — though other agencies, such as the FCC for a device that emits radio-frequency energy, can still apply.