Welcome to the Bureau Veritas Web Seminar

Overview of CPSIA
General Conformity Certificate and
Third Party Test Requirements
October 28, 2008
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 CPSIA Overview
General Conformity Certificate and Third Party Reports

Key Points
Consumer Product Safety Improvement Act

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Consumer Product Safety Improvement Act

► Children’s Product – a consumer product designed or intended primarily for children 12

years of age and younger

 Determined by:

• Manufacturer’s stated intent and labelling

• How the product is promoted or advertised

• Whether the product is commonly recognized for use by children

• CPSC Age Determination Guidelines

► Consumer Product – CPSA defines a consumer product as

 “any article, or component part thereof, produced or distributed

• (i) for sale to a consumer for use in or around a permanent or temporary household or
residence, a school, in recreation, or otherwise, or

• (ii) for the personal use, consumption or enjoyment of a consumer in or around a permanent
or temporary household or residence, a school, in recreation, or otherwise…”

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Consumer Product Safety Improvement Act
► Certification Requirements - General Conformity Assessment

 Every manufacturer of a product which is subject to a consumer product safety rule or a similar
rule, ban, standard or regulation enforced under the CPSC and being imported for consumption
or distributed shall issue a certificate:
• Adult and children's products
• Based on a reasonable testing program
• CPSC has 15 months to define “reasonable testing program”
• Shall list each rule, ban, standard and requirement applicable to the product
• Effective 90 days after enactment (Nov 12, 2008)
• Only enforceable by CPSC (not FDA, EPA, FCC, DOT, etc.)
• CPSC considers manufacturers as agents, brands, importers of record, private labelers
• CPSC will allow electronic certificates to “accompany” shipments if:
• the certificate has a unique identifier
• can be reasonably accessed
• the unique identifier was created in advance and available with shipment
 It is the Manufacturer’s responsibility
• Labs can not issue the General Conformity Assessment on your behalf

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List of all federally regulated products

► http://www.cpsc.gov/businfo/reg1.html

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CPSIA Requirement - Certificates

Manufacturers are required to submit a certificate stating the product complies with all
applicable safety rules/bans/requirements.

The certificate is based on….

• Adult and children’s item – Testing or reasonable testing program

Manufacturer’s Certificate
All applicable safety rules and
We certif y this product….
bans that apply to the
product, whether adult or
children’s item.

Complies with…. Must include:

• product descriptions
• manufacture date and place
• date and place product was tested
• each parties name, full mailing address, telephone
number
• contact information of individual storing the records
Signature

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Consumer Product Safety Improvement Act
► Third Party Test Reports
 Applies to children’s products subject to a children’s product safety rule with the
requirements phased in over a period of time.
• Third party lab must be accredited to 17025 which includes the scope of the
regulation by an ILAC signatory
• Must register and be approved by the CPSC
• First party labs must be “fire walled”
• Testing must be completed before importing for consumption or warehousing
• Does not apply to inventory
• Based on manufacturing date
 First - third party testing requirement is for 16 CFR 1303 – Dec 21, 2008
• Only applies to the children’s portion of 16 CFR 1303
 Based on CPSC policies
• Compositing should not be used when testing
• All materials are tested
• Final product testing only; no component testing
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CPSIA Certificate Timeline - General
General Conformity Assessment Certificate (adult or children’s product)
Examples: 16CFR1500.44 Flammability of Solids, 16CFR 1500 Mechanical Hazards

Aug 14, 2008 Nov 12, 2008

CPSIA enacted Manufacturer’s Certificate

required for product
manufactured on/after this
date

90 Days

Third Party Testing of Children’s Products

Examples: Lead paint, small parts, children’s jewelry, lead in substrates, phthalates, ASTM F963

CPSC Publishes 3rd Party Report required

Accreditation requirements – per test for product manufactured on/after this date

90 Days
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 CPSIA – Key Reporting Milestones
Manufacturers certify compliance to these requirements…
Manufacturer’s
Certificate
• Lead in Substrates (600 ppm) • Lead in Substrates (300 ppm)
(All Products)
• Phthalates • Lead Coatings (90 ppm)
Existing
• ASTM F963
Requirements
Enactment
Aug 14, 2008
Nov 12 Dec 21 Jan Feb 10 March June Aug 14 Sept
(90) (180) (360)

2008 2009

Lead in Coatings Lead in

(600 ppm) Small Parts Substrates
(300 ppm)

Cribs – Full and non full Children’s Jewelry

• All other
sized and Pacifiers CPSC
Bouncer, walkers, and
rules:
jumpers
• Phthalates
3rd Party Report …plus these with third party reports for children’s • F963
Requirements products manufactured on/after these dates.
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CPSIA Certificates – Example 1
Inventory Example – Children’s toy product manufactured on June 1, 2008,
distributed on/after February 10, 2009

GCC NO GCC needed

Manufacturer’s Certificate

We certif y this product….

Product must meet:
• Flammability
• Mechanical Hazards/Small Parts
• Lead in Coatings (600 ppm)
• Lead in Substrates
Complies with….
• Phthalates

Based on a reasonable testing program

Signature

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CPSIA Certificates – Example 2

Example – Children’s toy product manufactured on February 15, 2009

Manufacturer’s Certificate Statement for: Third Party Report

• Flammability
We certif y this product….
• Lead in substrates
(600 ppm)
• Phthalates Tested this product….
• ASTM F963
• Mechanical
Complies with….
hazards/small parts
• Lead in coatings
(600 ppm)

Complies with…

Signature Signature

Statement based on third

party report for:
• Lead in coatings (600 ppm)
• Small parts

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 CPSIA – Phthalates Example

GCC
Manufactured after…

GCC
GCC 3rd PR

Based on
reasonable testing
+
program

(No phthalates Manufactured during…

statement )
Period 2
Manufactured during…
Period 1
Nov 12 Feb 10 Sept

2008 2009

Phthalates Phthalates
CPSIA 3rd Party
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Consumer Product Safety Improvement Act

► Lead and phthalate requirements for product in inventory

 Product on the shelves in February of 2009 are expected to be in compliance

with the new lead and phthalate requirements
• 600 ppm total lead content in substrate material
• Particular phthalate content not exceeding 0.1% for products under the
scope
 Many products in inventory have not been tested to the substrate and
phthalate requirements – what can be done?
• Only consider products that will not be sold through by February 2009
• Risk assessment to rule out low risk products
• Screen by using XRF, compositing, etc
• Look to manufacturers or others for test reports indicating compliance
• Export suspect product

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Consumer Product Safety Improvement Act

► New Offering

 General Conformity Assessment Certificate – This is the self-declaration

document that must be issued for importation and distribution by the
vendor/manufacturer stating that their product meets all rules, bans, standards
and regulations applicable to their product.
• BVCPS can provide the document template based on our testing
• Recommend signed by the vendor/manufacturer as their own
self-declaration.
 Third Party Test Report – a test report that indicates third party testing was
conducted and the product meets the requirements as scheduled and phased
in by the CPSC, starting with lead in surface coatings on December 21, 2008.
This is the second document that will be required upon request at importation.
• Results will be transferred from a manufacturer’s own report or a retail test
report if tested under CPSC rules (e.g., no compositing, final product
testing).

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Resources – BureauVeritas.com/cps
www.bureauveritas.com/cps

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Resources - BureauVeritas.com/cps

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Resources – CPSC.gov
www.cpsc.gov/about/cpsia/cpsia.html

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Questions?

For more information, please contact the Bureau Veritas Analytical Team
at:

Email: analyticalservices@us.bureauveritas.com
or
ToyJPTechnicalServicesAmericas@us.bureauveritas.com
Bureau Veritas Consumer Products Services, Inc. (“BVCPS”) provides the information in this webinar as a resource of general i nformation. It does not replace any applicable legal or
regulatory requirements and is provided “as is.” BVCPS will not be liable for any indirect, special, punitive, consequential or other damages (including without limitation lost profits) of any
kind in connection with this webinar. BVCPS DISCLAIMS ALL REPRESENTATIONS AND WARRANTIES, EXPRESS OR IMPLIED, INCLUDING WITH OUT LIMITATION WARRANTIES
OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE, IN CONNECTION WITH THIS WEBINAR.
Copyright © 2007 Bureau Veritas Consumer Products Services, Inc. All Rights Reserved.

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