CPSC Testing and Certification Rule

11 Feb 2013

Feb. 8, 2013 marked an important date for U.S. domestic manufacturers and importers of children’s products.

Are you ready for the CPSC Testing and Certification Rule?

Feb. 8, 2013 marked an important date for U.S. domestic manufacturers and importers of children's products: it's the day that the U.S. Consumer Product Safety Commission's (CPSC) Testing and Certification Rule finally goes into effect. In short, this means that any children's product manufactured after this date must meet additional recordkeeping requirements in order to be compliant with the Rule.
What constitutes a children's product?

The Consumer Product Safety Improvement Act (CPSIA) defines a "children's product" as a "consumer product designed or intended primarily for children 12 years of age or younger."

This includes everything from toys and clothing to books and bibs.

What are your new obligations under the Testing and Certification Rule?

Domestic manufacturers and importers of children's products will now have to:

• Conduct periodic testing to provide a high degree of assurance that standards applicable to product continue to be met
• Perform retesting andrecertification if a product undergoes a material change
• Develop training and policies to prevent undue influence over third-party labs

How do you prove these obligations have been met?

Documentation of your efforts must be stored in a comprehensive technical file.

What needs to be included in the technical file?

1. Certificates (CPCs), including product test reports
2. Periodic/Production Testing Plan (PTP)
3. Sampling Procedure used to select "representative" samples for periodic/production testing
4. Actions taken in response to a test sample failure
5. Material Changes and responses thereto
6. Undue Influence policies and training
7. All records must be kept for 5 years and provided (and translated into English, if necessary) IF the CPSC asks for the records

Do you have a question about the CPSC Testing and Certification Rule or related topics? Please leave your comment below and one of our experts will get back to you.