CPSC Section 15(b) Reporting for Amazon Sellers: Who Must Report, the 24-Hour Clock, and the 10-Working-Day Cap

CPSC Section 15(b) reporting is the federal duty of manufacturers, importers, distributors and retailers of consumer products to tell the U.S. Consumer Product Safety Commission (CPSC) when they obtain information that reasonably supports the conclusion that a product has a defect that could create a substantial product hazard, creates an unreasonable risk of serious injury or death, or fails to comply with an applicable safety rule. The deadline is 24 hours from obtaining that information. If you are unsure whether it is reportable, CPSC allows a short investigation, which should not exceed 10 working days. Amazon sellers fall inside this duty in whichever of those four roles they occupy.

This guide covers the legal reporting duty itself. What Amazon does to your listings once a recall is underway is a separate process, covered in our Amazon product recalls guide. Nothing here decides whether a specific incident is reportable; that call belongs to your company, and CPSC staff will discuss it with you.

Sources: CPSC “Duty to Report to the CPSC: Your Rights and Responsibilities” page, CPSC’s Product Safety Planning, Reporting, and Recall Handbook (PDF, page footer “Revised August, 2021”), and the SaferProducts.gov Section 15 report form. Data checked 2026-10-08.

Who Has a Duty to Report Under Section 15(b)

CPSC’s Duty to Report page names four roles: manufacturer, importer, distributor and retailer of consumer products. All four carry the obligation to report immediately. Most Amazon sellers occupy at least one of these roles, and many occupy two.

Write down which role you hold for each product line before anything goes wrong, so nobody spends the first day of an incident debating it. Our Manage Your Compliance guide shows where Amazon asks you for the matching documents.

The Five Triggers and Who Each One Applies To

The CPSC Duty to Report page lists five situations that require a report; the handbook adds the deadline and channel for each. The table’s trigger wording follows the handbook and statute, not that page’s text. Choking incidents and lawsuits fall under separate statutes, but CPSC presents all five together.

A few details matter for Amazon catalogs:

• Rule violations are broad. The handbook’s list covers the CPSA plus other acts CPSC enforces, such as the Flammable Fabrics Act and the Federal Hazardous Substances Act. Our Children’s Product Certificate guide covers the testing side.
• You do not need a root cause. The handbook states that “a reporting obligation arises even if a firm cannot identify a defect and/or root cause.”
• Choking reports have a threshold. Per the handbook, the child (of any age) must have choked on the item and, as a result, died, suffered serious injury, stopped breathing for any length of time, or been treated by a medical professional. “Small ball” means a diameter of 1.75 inches or less.
• Lawsuit reports cover two-year windows. The current window runs January 1, 2025 to December 31, 2026, per the handbook’s list.

The 24-Hour Clock and the 10-Working-Day Investigation Cap

The handbook spells out the timing in one sentence: “A company must report to the CPSC within 24 hours of obtaining reportable information.” CPSC encourages reporting while your own investigation is still running.

The 10-working-day cap only applies when you genuinely do not know yet. The handbook’s wording: “if a company is uncertain about whether information is reportable, the company can take a reasonable time to investigate the matter. That investigation should not exceed 10 working days, unless the company can demonstrate that a longer time is reasonable under the circumstances.” After 10 working days, CPSC presumes you have gathered everything a reasonable, expeditious and diligent investigation would have found.

Three rules decide when the clock actually starts:

1. Knowledge starts with any capable employee. CPSC treats your company as knowing when the information reaches “an employee or official of the company, who may reasonably be expected to appreciate the significance of that information.” For a small seller, that can be whoever reads buyer messages.
2. Five working days to reach the top. Under ordinary circumstances, the handbook sets 5 working days as the maximum reasonable time for that information to reach the CEO or the person responsible for reporting.
3. You are deemed to know what due care would reveal. CPSC judges late reporting partly on what “a reasonable person, acting under the circumstances, should have known.” Unread complaints do not stop the clock.

If information suggests a product caused, may have caused, contributed to, or could contribute to a death or grievous bodily injury, the handbook says the firm must report unless it has investigated and determined the information is not reportable. CPSC compliance staff’s consistent advice, quoted in both sources: “When in doubt, report.”

What Counts as Reportable Information for an Amazon Seller

The handbook lists the kinds of information firms should monitor: consumer complaints, warranty returns, insurance claims or payments, product liability lawsuits, reports of production problems, product testing, and other critical analyses of products.

On Amazon, we map those categories to:

• Buyer-Seller Messages that describe burns, shocks, cuts, breakage or a child putting a part in their mouth.
• Return reasons and return comments, especially “defective” returns that describe overheating or something coming apart.
• Product reviews and A-to-z claims that describe injury or a safety failure.
• Supplier test reports that come back failing, including retests after a component change.
• Insurance claims filed under your product liability policy (see our product liability insurance guide).
• Amazon or carrier notices about a battery, fire or leak incident. Lithium battery products deserve extra attention; our FBA lithium battery guide covers the classification side.

None of these automatically requires a report, but this is where the clock tends to start unnoticed.

Retailers and Distributors: Three Ways to Meet the Duty

For sellers who did not make or import the product, the handbook gives three routes to satisfy the initial reporting obligation:

1. Report the required information directly to CPSC’s Office of Compliance and Field Operations through the Section 15 mailbox.
2. Send a written communication to the manufacturer or importer describing the possible defect, non-compliance or risk, and send a copy of that communication to the Office of Compliance and Field Operations.
3. Forward reportable information you received from another company to the Office of Compliance and Field Operations.

There is one exception. You do not need to report if you have actual knowledge that CPSC has already been “adequately informed,” for example because the manufacturer gave you a copy of the full report it filed. Retailers and distributors must include the required information “insofar as it is known to the retailer or distributor,” per the handbook’s citation of 16 CFR 1115.13(b).

Route 2 trips up resellers most often. Emailing the brand alone does not satisfy the duty; CPSC must receive the copy.

What a Written Initial Report Contains

The handbook says a report “should not be delayed because some of this information is not yet available.” The initial written report, under 16 CFR 1115.13(c), covers:

• Identification and description of the product
• Name and address of the manufacturer and/or importer, or if unknown, all known distributors and retailers
• Nature and extent of the possible defect, failure to comply, or risk
• Nature and extent of injury or risk of injury
• Name and address of the person informing the Commission
• If reasonably available, the other information in 16 CFR 1115.13(d)
• A timetable for providing information not yet available

CPSC staff may then request more, such as complaint records, test reports, UPC codes, product samples and foreign manufacturer details.

Where to File: SaferProducts.gov or the Section 15 Mailbox

The handbook says Section 15 reports should be filed electronically through SaferProducts.gov, or by email to [email protected] with “Section 15” in the subject line. The SaferProducts.gov Section 15 form describes itself as the way to report under section 15(b) of the Consumer Product Safety Act. It starts with product description, brand name and model numbers. At the end of an initial report, it offers the option to proceed into CPSC’s Fast Track Product Recall Program.

The CPSC hotline listed in the handbook is (800) 638-2772. Choking reports go to [email protected] and lawsuit reports to [email protected], each with the section number in the subject line.

Confidentiality: What CPSC Can Release

According to the handbook, Section 6(b)(5) of the CPSA prohibits CPSC from releasing information reported under Section 15(b) unless one of the following applies: a remedial action plan has been accepted in writing, a complaint has been issued, the reporting company consents, or the Commission publishes a finding that public health and safety require disclosure with less than 15 days’ notice. Separately, you can claim trade-secret or confidential commercial treatment by marking material “confidential” when you submit it. Choking reports get the same confidentiality treatment.

Filing a report does not mean CPSC will order a recall. The handbook notes that many reports “require no corrective action” after staff review.

Penalties for Late or Missing Reports

CPSC’s Duty to Report page warns that failure to report fully and immediately may lead to “substantial civil or criminal penalties” without stating amounts. The handbook adds that CPSC can assess civil penalties for a knowing failure to file a timely report, and that criminal penalties can result if the violation is also willful.

On amounts: a CPSC staff ballot package dated November 17, 2021 set the inflation-adjusted maximums at $120,000 for each violation and $17,150,000 for a related series of violations, applying to violations after January 1, 2022. That same document says the CPSA requires a new schedule by December 1 of every fifth year, so a revision is due by December 1, 2026. Check CPSC for the current figures before relying on these.

What to Do Before You File

Use this checklist the day a safety signal appears:

• Record the date and time the information first reached your team, and who received it.
• Identify your role for this product: manufacturer, importer, distributor or retailer.
• Classify the trigger: defect, serious risk, rule violation, choking incident or lawsuit.
• Pull every related message, return comment, review, claim and test report.
• Gather product identification: ASINs, model numbers, UPCs, units sold and dates.
• Contact the manufacturer or importer if you are a reseller, and copy CPSC if you use that route.
• Set a hard internal deadline inside 10 working days if you are still investigating.
• Mark any trade-secret material “confidential” before submitting.
• Decide whether to file through SaferProducts.gov or the Section 15 mailbox, and who will sign.

If the product also needs eFiled certificates at import, keep those records aligned; our CPSC eFiling guide explains that side.

Common Mistakes

• Waiting for a root cause. CPSC says the duty can arise without one.
• Treating 10 working days as a grace period. It caps an investigation of genuinely uncertain information; it does not delay the 24-hour rule.
• Assuming the brand reported it. Retailers are excused only with actual knowledge that CPSC was adequately informed.
• Emailing the manufacturer without copying CPSC. That route requires the copy.
• Sending a choking report to the Section 15 mailbox. It goes to [email protected].

Frequently Asked Questions

Does an Amazon reseller have to report to CPSC, or only the brand?

CPSC’s Duty to Report page lists retailers and distributors alongside manufacturers and importers. A reseller can meet the duty by reporting directly or by writing to the manufacturer or importer and copying CPSC, per the handbook.

When does the 24-hour clock start?

When reportable information reaches an employee or official who can reasonably be expected to appreciate its significance, according to the CPSC handbook. For many sellers, that is whoever handles customer messages.

Is the 10-working-day investigation always allowed?

Only when a company is uncertain whether information is reportable. The handbook says the investigation should not exceed 10 working days unless a longer time is reasonable under the circumstances.

Will CPSC make my report public?

Section 6(b)(5) of the CPSA bars release of Section 15(b) information except in listed circumstances, such as an accepted remedial plan or your consent.

Conclusion

Section 15(b) gives every supply-chain role, Amazon resellers included, a 24-hour duty once reportable information reaches the company. Map your role in advance, route safety signals to one decision-maker, and file when in doubt. For the Amazon side of what follows, see our product recalls guide.