Certification Requirement for Conformity Testing and 3rd Party Testing

Section 102 of the Consumer Product Safety Improvement Act (CPSIA) Request for Comments and Questions

Section 102 of the CPSIA addresses new requirements for certificates for general conformity testing and third party testing for children’s products.

Section 102 requires each manufacturer (including importer) of any consumer product to issue a certificate that the product complies with CPSC rules under the CPSIA or similar requirements under any of the other Acts administered by the CPSC. The certificate must be based on a test of each product or on a reasonable testing program. This requirement is effective beginning on November 12, 2008. There are additional third party testing requirements for children's products.

In addition, the section requires that every certificate “shall accompany the applicable product or shipment of products covered by the same certificate and a copy of the certificate shall be furnished to each distributor or retailer of the product.

TIA recommends member companies submit all comments and questions regarding Section 102 to the Consumer Product Safety Commission (CPSC) no latter than October 29, 2008.  In particular, the CPSC staff is requesting comments on the use of electronic certificates as well as the issue of multiple certifications for the same product.

Submit comments and questions by email to cpsc-os@cpsc.gov, or by facsimile to (301) 504-0127 or by mail or delivery to the Office of the Secretary, Consumer Product Safety Commission, Room 502, 4330 East-West Highway, Bethesda, Maryland. Comments should be captioned “Section 102 Certificate Requirements."

TIA members may also submit copies and comments to TIA via cpsiainfo@toyassocaition.org for possible inclusion into the industry statement TIA will deliver to the commission.