Compliant Always
Get in touch

Selling other consumer goods in the US

In the US, a consumer product subject to a Consumer Product Safety Commission rule needs a certificate of compliance naming the rules it meets. The certificate travels with the product and, for imports, is eFiled with Customs at entry. Packages show identity, net quantity and who stands behind them, under the Fair Packaging and Labeling Act.

Updated · Each section links to the official source it comes from

Covers
Packaged non-food products without a guide of their own
Safety rules
Consumer Product Safety Act and CPSC rules
Certificates
16 CFR Part 1110
Imports
Certificate data eFiled with Customs at entry
Packaging labels
Fair Packaging and Labeling Act, 16 CFR Part 500
States
Can add rules, such as California's Proposition 65

Before a product goes on sale

The questions to answer, in the order they usually come up.

  1. 1Is the product subject to a CPSC rule, ban or standard? Read more
  2. 2Is there a certificate that identifies the product and the rules it meets? Read more
  3. 3If it is imported, is the certificate eFiled at entry? Read more
  4. 4Does the package show identity, net quantity and who stands behind it? Read more
  5. 5Is there a way to report a defect to the CPSC within 24 hours? Read more
  6. 6Is it a toy, electronic product, textile, cleaner or kitchen article, with its own guide? Read more

The rules, by area

What each area covers, the texts that set it, and what the official pages say.

Certificates of compliance

The certificate that states which safety rules a product meets.

  • 16 CFR Part 1110 says who must issue certificates for finished products under section 14(a) of the Consumer Product Safety Act, and what they contain.
  • A certificate identifies the product by at least one unique identifier, such as a GTIN, model number, SKU or UPC, and states each rule, ban, standard or regulation it is certified to.
  • A certificate accompanies each finished product or shipment that must be certified, and describes only one product.
  • Importers of finished products that must be certified eFile the certificate data with US Customs and Border Protection at entry.

How we help: Compliant Always keeps each certificate with the product and the test reports it rests on, so the eFile data and the certificate agree. Ask about this

Records and the CPSC label

What a certifier keeps, and the optional statement on the product.

  • Certifiers keep finished product certificates and the test records behind them for at least five years from the certificate date.
  • Certificates are furnished to each distributor and retailer, and made available to the CPSC or Customs within 24 hours of a request.
  • The importer of a foreign-made product, or the US manufacturer, certifies it; the certifier stays legally responsible for the certificate even where another party tests or enters data.
  • A certified product may carry the statement 'Meets CPSC Safety Requirements', provided it does not imply that the CPSC tested or endorsed it.

How we help: Compliant Always keeps certificates and test records dated, shows when a record nears the end of its keeping period, and answers retailers' certificate requests from the record. Ask about this

Defect reporting

Telling the CPSC about a product hazard.

  • A firm reports to the CPSC when it obtains information indicating that a consumer product it has distributed fails a CPSC standard or ban, has a defect that could create a substantial product hazard, or creates an unreasonable risk of serious injury or death.
  • It should report within 24 hours of obtaining information that reasonably supports that conclusion, without waiting to be certain.
  • Complaints, injury claims, production data and independent laboratory results are among the information a firm evaluates.
  • Some product classes, such as hair dryers without immersion protection, are deemed substantial product hazards by rule.

How we help: Compliant Always keeps complaints, test reports and production records with the product and lot, so the facts behind a reporting decision are in one place. Ask about this

Packaging and labelling

What the package of a consumer commodity shows.

  • The principal display panel states the identity of the commodity, as a principal feature, easy to read.
  • The label names the manufacturer, packer or distributor and its place of business, conspicuously; where the named business did not make the product, a phrase shows its connection.
  • The net quantity of contents is declared on the principal display panel, as a distinct item.

How we help: Compliant Always sets your package beside the labelling rules, line by line, with the regulation for each. Ask about this

Products with their own guide

Where to look for toys, electronics, textiles, cleaners and kitchenware.

  • Toys follow ASTM F963-23 under 16 CFR 1250, with third party testing and a Children's Product Certificate: see the toys guide.
  • Radio and digital devices need FCC equipment authorisation, and some appliances an EnergyGuide label: see the electrical and electronics guide.
  • Clothing, bedding and other textiles carry fibre, origin and care labels and meet flammability standards: see the clothing, footwear and textiles guide.
  • Household cleaners carry FHSA hazard labels, and disinfectants are pesticides registered with the EPA: see the cleaning products guide.
  • Cookware, tableware and containers are regulated by the FDA as food contact articles: see the kitchenware guide.

How we help: Compliant Always works out which guide's rules apply to a product that falls between classes, and keeps the evidence for each. Ask about this

Who answers for what

WhoWhat they answer forHow we help
ManufacturerCertifying products made in the US to the rules that apply.Certificates and test reports kept together by product.
ImporterCertifying imported products, and eFiling the certificate data at entry.Overseas suppliers' test reports read and dated before the goods ship.
Brand or distributorThe package label, where its name appears on it.Package labels checked against the rules, with the paperwork behind them.

Federal and state

Federal agencies set the national rules. States can add their own: California's Proposition 65, for example, can call for a warning on a product sold there.

Retailers and marketplaces often ask for more than the law does, such as test reports by lot or third party certificates.

Questions businesses ask

Which consumer products need a certificate of compliance?
Finished products subject to a consumer product safety rule, or a similar rule, ban, standard or regulation enforced by the Consumer Product Safety Commission, under section 14 of the Consumer Product Safety Act.
What does a certificate of compliance contain?
At least one unique identifier for the product, such as a GTIN, model number, SKU or UPC, and each rule, ban, standard or regulation the product is certified to, among other content set in 16 CFR 1110.11.
Does the certificate travel with the product?
Yes. A certificate accompanies each finished product or shipment that must be certified, and each certificate describes only one product.
What changes for imported products?
The importer eFiles the certificate data with US Customs and Border Protection when the entry is filed, for finished products that must be certified.
What does a US consumer product package have to show?
Under the Fair Packaging and Labeling Act regulations: the identity of the commodity, the net quantity of contents on the principal display panel, and the name and place of business of the manufacturer, packer or distributor.
Does the regulation say how a product must be tested?
Part 1110 does not set the type or frequency of testing behind a certificate; it covers who certifies, the content, form and availability, and eFiling.
How long are certificate records kept?
At least five years from the date the certificate was created, together with the test results it is based on.
When must a consumer product defect be reported to the CPSC?
Within 24 hours of obtaining information that reasonably supports the conclusion that a product fails a CPSC rule, has a defect that could create a substantial product hazard, or creates an unreasonable risk of serious injury or death.
Can a product say 'Meets CPSC Safety Requirements'?
Yes, if the manufacturer or private labeler has certified it to the applicable CPSC rules, and the label does not imply that the CPSC tested or endorsed it.
Where are toys, electronics and clothing covered?
Each has its own guide: toys, electrical and electronics, clothing and textiles, cleaning products, and kitchenware. This guide covers other packaged non-food products.
Do states add their own rules?
They can. California's Proposition 65, for example, can call for a warning on a product sold there.
Can I label a product "Made in USA"?
Only if it is all or virtually all made in the US. The FTC's Made in USA Labeling Rule, 16 CFR part 323, applies to labels, including online and in catalogues, and covers implied claims such as flags.
How does Compliant Always help with selling in the US?
Our team reads the rules for the markets you sell in. Compliant Always shows which apply to your product, keeps the documents behind each one ready, and watches federal sources for changes. It shows what the requirements say and what your documents show; you decide.

Sources

Compliant Always is a product of Lettuce Labs LLC. It shows what requirements say and what your documents show. It is not legal advice, and you decide.

Tell us what you make, and we will show you the rules for it.

Name the product and the markets you sell in. We will come back to you with what applies in the US and what your paperwork needs to show.

Get in touch

No card, no account, and no call to book. Tell us what you make and where you sell it, and we will come back to you.

Get in touch