A Children’s Product Certificate (CPC) is a written certificate, issued by the US manufacturer or, for anything made abroad, the importer, stating that a children’s product passed testing at a third-party, CPSC-accepted laboratory against every children’s product safety rule that applies to it. For an Amazon seller importing kids’ goods from an overseas factory, the certifier is the importer of record, not the factory: CPSC’s FAQ, read on 2026-10-05, says “an importer cannot simply pass along a foreign manufacturer’s certificate of conformity.” Amazon asks for a CPC through its compliance requests and lists what the certificate must carry.
This guide covers the certificate itself. Where Amazon’s requests appear in Seller Central, and how to upload or appeal them, is in our Manage Your Compliance guide.
The Sources, and How Current They Are
| Source | What it settles |
|---|---|
| CPSC: Children’s Product Certificate | Seven elements, English rule, eFiling notice |
| CPSC: CPC FAQ | Who certifies, foreign certificates, furnishing |
| CPSC: Children’s Products | The age-12 definition and four factors |
| CPSC: Certificates and eFiling | Effective dates of the revised rule |
| 16 CFR part 1110, § 1107.26 (eCFR, text as of 2026-10-01) | The regulation: certifier, content, records |
| Amazon: Product compliance documentation (US) | What Amazon wants on a CPC and test reports |
All pages were read on 2026-10-05. CPSC’s pages are not fully in sync: the CPC guidance page still lists the original seven elements, while revised part 1110, which CPSC says took effect July 8, 2026, asks for more. The FAQ still says CPSC “does not require you to file a CPC with the agency at this time,” which no longer describes imports. Where they differ, this guide says which is newer.
Is Your Product a “Children’s Product”?
CPSC defines a children’s product as “a consumer product designed or intended primarily for children 12 years of age or younger.” Its Children’s Products page lists four factors:
- The manufacturer’s statement about intended use, including the label, if reasonable.
- Whether packaging, display, promotion, or advertising present it as suitable for children 12 or under.
- Whether consumers commonly recognize it as intended for a child 12 or under.
- CPSC staff’s Age Determination Guidelines (January 2020) and any successor.
Factor 2 matters on Amazon because your listing is advertising. Kid-themed photos or a “kids’ size” bullet push a product toward children’s product status, whatever the factory spec sheet says. A CPC is needed when the product is a children’s product and at least one children’s product safety rule applies; CPSC’s CPC page links the list of those rules.
If Amazon has flagged an adult product as a children’s product, that is a classification question for an appeal, not a certificate.
Who Issues the CPC, and Why the Factory’s Certificate Is Not Enough
16 CFR § 1110.7 sets the certifier. For a product made outside the United States, “the importer, as defined in this part, is the finished product certifier.” For a US-made product, the manufacturer certifies, or the private labeler if the manufacturer has not.
Section 1110.3 defines “importer” as the Importer of Record (IOR), “who may be an owner, purchaser, or authorized customs broker.” For a private label seller shipping into FBA, the certifier is whoever appears as IOR on the customs entry; confirm that with your customs broker before drafting anything.
Three points from CPSC’s FAQ settle most confusion:
- The factory cannot certify your import. A certificate naming the factory as certifier does not meet the rule; the importer “cannot simply pass along” it.
- You may rely on the factory’s testing. 16 CFR part 1109 lets an importer base its CPC on another party’s testing if the importer “exercises due care” and has access to the underlying test reports and related records, such as test plans.
- You do not need to be in the US. The FAQ says “the importer does not need to be located physically within the United States, nor do they need to list a U.S.-based address to comply with elements 3 and/or 4 of the CPC.”
Paperwork help does not move the liability: the importer “is always legally responsible for issuing a CPC, even if a third-party testing laboratory, or another third party, drafts or assists with drafting the CPC.” CPSC adds that “Creating a CPC has no cost.”
The working order: the factory or your sourcing agent arranges testing at a CPSC-accepted lab, you get the full report, and your company issues the CPC in its own name.
The Required Elements: Old List vs. Current Rule
CPSC’s guidance page and Amazon’s help page both list seven elements. The revised § 1110.11(a) keeps seven items but asks for more detail and replaces the separate lab item with an attestation.
| # | CPSC guidance page | Revised 16 CFR § 1110.11(a) |
|---|---|---|
| 1 | Product identification | At least one unique identifier (GTIN, model number, SKU, UPC, serial number, or similar) plus a matching description |
| 2 | Each applicable children’s product safety rule | Each rule listed separately |
| 3 | Certifying manufacturer or importer: name, mailing address, phone | Name, street address, city, country, email, phone |
| 4 | Records-keeper: name, mailing address, email, phone | Same; may be a position title if always staffed and responsive |
| 5 | Date and place of manufacture: month/year; city, state (if applicable), country | Month/year plus manufacturer name, street address, email, phone |
| 6 | Date(s) and place(s) of testing | Most recent test date and place, with each testing body’s address, email, phone |
| 7 | The third-party, CPSC-accepted lab | Certifier’s attestation, acknowledging it is “a United States federal crime” to knowingly make a materially false statement |
Two further changes. If you claim a testing exclusion for a rule, § 1110.11(c) says the certificate “shall identify the applicable testing exclusion” in place of test date and place for that rule. And the language rule stands: “The CPC and supporting test reports must be in English,” per CPSC’s guidance; § 1110.9 allows the same content repeated in another language.
Build your template to the revised list. A certificate with a SKU or UPC, full street addresses and emails for every party, and the attestation also covers the older list and Amazon’s page.
On signatures, CPSC’s FAQ answers “Do I have to sign the CPC?” with “No; however, the certifier is legally responsible for the accuracy and integrity of the data supplied on a CPC.”
The Testing Behind It: CPSC-Accepted Labs
A children’s product subject to a children’s product safety rule must be tested by “a third-party, CPSC-accepted laboratory,” per CPSC’s CPC page.
“Accepted” is narrower than “accredited.” Amazon’s help page: “The test report must be from a CPSC accepted laboratory. In addition to CPSC acceptance, the testing laboratory also must be accredited to perform the required testing standard.” Each lab is accepted for specific rules, so check its scope against the rules your CPC cites.
Registered small batch manufacturers may skip third-party testing for certain rules and must put their CPSC registration number in the lab section of the CPC. Amazon notes that “certain children’s products must be third party tested at a CPSC-accepted laboratory, even if manufactured by an SBM.”
Furnishing, Records, and the 2026 eFiling Rule
- Distributors and retailers. CPSA section 14(g)(3) requires CPCs to be “furnished” to them; “a reasonable means to access the certificate, either physically or electronically” satisfies it, per CPSC’s FAQ.
- Regulators. § 1110.13: available “within 24 hours, upon request by CPSC or CBP.”
- Every shipment must be “accompanied” by the certificate; electronic accompaniment works.
- Consumers. “CPSC does not require you to provide the certificate to consumers.”
- Batches. One CPC can cover materially unchanged shipments if it describes the date range covered.
- Records. § 1110.17: keep certificates and supporting records “for at least five years from the certificate creation date.” § 1107.26 lists the record set, including test records per manufacturing site and records of material changes.
eFiling is the 2026 change. CPSC’s CPC page states: “Beginning July 8, 2026, importers of most regulated consumer products will be required to electronically file (eFile) certificates of compliance with U.S. Customs and Border Protection (CBP).” Its certificates page gives January 8, 2027 for goods entered from a Foreign Trade Zone and says the requirement “does NOT apply to products that are domestically manufactured,” though US makers must follow the new content rules. For an FBA importer, the CPC data has to exist before goods clear customs, not when Amazon first asks.
Failing to furnish a certificate, knowingly issuing a false one, or skipping required testing “is subject to CPSC enforcement under several statutes, including 15 U.S.C. 2068(a)(6),” per CPSC’s FAQ.
What Amazon Asks For
Amazon’s help page ties its list to a request: “If Amazon requests a CPC, the certificate you provide must include all of the following information.” The list mirrors CPSC’s seven elements, asks for the factory’s street address when the manufacturer runs several sites in one city, and names the “importer or U.S. domestic manufacturer that certifies the product,” so a factory-issued certificate does not fit Amazon’s list either.
Test reports often come with the request: they “must be from independent, third-party testing laboratories.” For ISO 17025 reports Amazon lists age grading as “required for children’s products,” a non-editable format, and a product image matching the ASIN. If the report’s make and model differ from your listing, for example after rebranding, Amazon may require an affidavit from the test report applicant.
If Amazon requests a tracking label, it must be permanent on product and packaging: “Do not provide a tracking label printed on paper and stuck on the product.”
Amazon’s page describes what to send when asked; it does not say a CPC must be on file before Amazon asks. CPSC’s rule applies either way. For category restrictions more broadly, see what you can sell as a new seller.
Common Mistakes
- Uploading the factory’s CPC. Wrong certifier for an import; reissue it in your name from the factory’s report.
- Certificate without the report. “Due care” needs access to the underlying reports.
- Lab accepted, wrong scope. The lab must be accepted for the rules you cite.
- Identifier mismatch. Report, CPC, and listing should share the model number or SKU.
- One CPC for a whole catalog. CPSC recommends “limiting the listed products to those similar in design.”
A CPC does not shield you from a recall; see Amazon product recalls and product liability insurance. Europe has its own framework, covered in our GPSR guide.
CPC Checklist
- Confirm children’s product status, including listing copy and images.
- List every applicable children’s product safety rule.
- Test at a CPSC-accepted lab whose scope covers those rules; get the full report.
- Confirm the Importer of Record; that party issues the CPC.
- Draft in English to revised § 1110.11, with identifier, emails, and attestation.
- Have certificate data ready for eFiling before goods enter the US.
- Furnish the CPC to distributors and retailers; keep records five years.
Frequently Asked Questions
Can my Chinese supplier issue the CPC for my Amazon product?
Not as certifier of your import. Under 16 CFR § 1110.7 the importer certifies products made abroad. You can base your CPC on the supplier’s CPSC-accepted lab testing if you exercise due care and can access the reports.
Do I need a US address to issue a CPC?
No. CPSC’s FAQ says the importer need not be in the United States or list a US-based address.
How long must I keep CPC records?
At least five years from the certificate creation date, under 16 CFR § 1110.17.
Do I have to file my CPC with CPSC?
For imports, from July 8, 2026 importers of most regulated consumer products must eFile certificate data with CBP, per CPSC. Domestically made products are outside eFiling.
Conclusion
A CPC is short, but it rests on the right rules, a CPSC-accepted lab with the right scope, a full test report, and an importer, not a factory, as certifier. Since July 8, 2026 imports also need the data eFiled. Build to the revised content list, keep identifiers matched, and Amazon’s request becomes a routine upload.