A recurring source of enforcement trouble for new importers is the assumption that a factory’s test report is the same thing as a Children’s Product Certificate. It is not. For imported goods the importer issues the certificate, and it must be based on testing of that product by a laboratory the CPSC accepts for the applicable rule.
Three details that decide whether a certificate holds up: the report covers the model actually being imported; the tests cover every applicable rule, not only lead content; and tracking labels are physically present on the product and packaging.
When a component supplier, a colourway or a factory changes, the basis of the certificate changes with it. Requirements and the list of accepted laboratories are published at cpsc.gov.
