GCC vs CPC: which certificate does your product need?
The difference is not paperwork preference. One requires testing at a CPSC-accepted lab, and since July 2026 imports must eFile both at entry.
Two certificates, similar names, completely different amounts of work. Picking the wrong one is the most common CPSIA mistake we see, and since July it has a new consequence: for imported products, the certificate data now has to reach Customs electronically at the moment of entry.
Checked against the regulations on September 29, 2026.
The short answer
| General Certificate of Conformity (GCC) | Children's Product Certificate (CPC) | |
|---|---|---|
| Authority | 15 U.S.C. 2063(a)(1) | 15 U.S.C. 2063(a)(2) |
| Applies to | Non-children's consumer products subject to a CPSC rule | Children's products subject to a children's product safety rule |
| Testing | Your own reasonable basis | Third party, at a CPSC-accepted lab |
| Cost | Low | The expensive one |
Both are defined in 16 CFR §1110.3. The substantive gap is the testing: a GCC rests on a reasonable testing basis you determine, while a CPC must be supported by testing at a third party conformity assessment body accredited for the specific rule.
Which one you need turns on one question
Is it a children's product? 16 CFR §1200.2(a)(1) defines that as "a consumer product designed or intended primarily for children 12 years of age or younger", and §1200.2(c) gives four factors, weighed together:
- A statement by the manufacturer about intended use, including a label, if reasonable.
- Whether the packaging, display, promotion or advertising represents it as appropriate for children 12 or under.
- Whether consumers commonly recognize it as intended for that age group.
- The CPSC's Age Determination Guidelines.
Note factor 1's qualifier: labeling something "not for children" does not settle it if the other three point the other way, because the factors are weighed as a whole, not passed one at a time.
The importer is the certifier
This is the part people outsource and shouldn't. From 16 CFR §1110.7:
for a finished product manufactured outside of the United States that must be accompanied by a certificate as set forth in § 1110.5, the importer, as defined in this part, is the finished product certifier that must issue a finished product certificate that meets the requirements of this part.
Not the factory. Not the broker. A certificate your supplier hands you is an input to your certificate — you are the one attesting.
What has to be on it
§1110.11 lists the required elements, and they are more specific than most templates:
- Product identification — GTIN, model, serial, SKU or UPC, plus enough description to identify it.
- Each applicable safety rule, ban, standard or regulation, listed separately.
- The certifier's name and full contact details.
- The record-keeper's name and contact details.
- Manufacturing date and place, with manufacturer details.
- The most recent testing date and place, and the testing body's contact details.
- The certifier's attestation.
"Complies with all applicable CPSC regulations" fails item 2. Each rule gets named.
The July 2026 change: it is now filed at entry
The final rule amending Part 1110 took effect July 8, 2026. For imported finished products, the certifier must now eFile the certificate data elements into CBP's Automated Commercial Environment at entry (§1110.13). Products entered from a foreign trade zone for consumption or warehousing follow on January 8, 2027 (see the correction that restated these as applicability dates).
The data that goes into CPSC's message set is the §1110.11 content above, sent either in full or as a reference to certificate data you have already entered in CPSC's Product Registry. The exact field layout is in CPSC's technical implementation guide for filers.
Two practical notes. In the final rule, CPSC said that, at least in the initial stages, it generally does not intend to ask CBP to deny entry solely because eFiled certificate data is missing — so a quiet entry is not evidence you filed correctly. And the agency was explicit that it will continue to enforce certificate requirements, including by refusing admission or asking CBP to seize non-compliant products. The soft landing is on entry, not the obligation.
A Product Registry exists for repeat shipments: you pre-load certificate data and give your broker a certificate identifier instead of the full set. It does not talk to ACE by itself — the broker still transmits.
What to do this week
- Sort your catalog into children's products and everything else, using the four factors rather than instinct.
- For each children's product, confirm you hold a CPC backed by third-party testing at a lab accepted for that rule — accreditation is scope-specific.
- Check your certificates name each rule separately and carry the most recent test date.
- Ask your broker what they are currently transmitting for you, and whether ACE is returning any messages on your entries.
Aleph keeps the certificates you issue and the lab reports behind them on each product, and emails you before the expiry dates you record, so "which of these is expiring" is a list rather than a search. You write, attest to, and file the certificate; Aleph does not generate it or file with CPSC or CBP.
General information, not legal advice. Every requirement above links to the regulation or statute — check those and talk to counsel about your catalog.