Generating a CPC for your children's product
Children's Product Certificate — what it must contain, who issues it, and where to keep it in Aleph.
A Children's Product Certificate (CPC) certifies, based on testing by an accredited third-party lab, that a children's product complies with each children's product safety rule that applies to it (15 U.S.C. 2063(a)(2)). For a product made outside the United States, the importer issues it (16 CFR 1110.7(a)).
What the certificate must contain (16 CFR 1110.11(a), as revised effective July 8, 2026):
- Product identification — at least one identifier (GTIN, model number, registered number, serial number, SKU, UPC, or an alternate identifier) and enough description to match the product to the certificate
- Each applicable rule — every rule, ban, standard, or regulation the product is certified to, listed separately
- The certifier — name, street address, city, state or province, country, email, and telephone number
- The records custodian — the same contact details for the person (or always-staffed position) who keeps the test records
- Date and place of manufacture — month and year at a minimum, and the manufacturer's name, full address, email, and telephone number
- Date and place of testing — the most recent testing, and each third-party lab relied on, with its name, address, email, and telephone number
- The attestation — the certifier's statement, in the wording the rule sets out, that the products comply and the information is true and accurate
Aleph doesn't generate the certificate for you. Issue it yourself (or have your compliance partner prepare it), then upload it with the lab reports on the product's Compliance tab using Upload document. A report you upload can be filed under more than one of the product's modules, but filing it there doesn't mean it meets another regulation's testing requirement. A CPSIA lab report tests to CPSIA rules, not to Prop 65 or state PFAS laws.
WARNING: A CPC has no fixed 12-month life, but it must stay backed by current testing. Periodic third-party testing is due at least once a year, or once every two or three years under the options in 16 CFR 1107.21. A material change to the product's design, manufacturing process, or component sourcing that could affect compliance requires new testing and a new CPC (16 CFR 1107.23(a)).