CPSIA - What is a General Conformity Certificate (GCC)?

I'm struggling very much with the interpretation of the CPSIA as it is intended for micro-manufacturers of handmade goods like me. I have been reading and turning it over in my mind. My goal is to stay in business while Congress and the CPSC figure out the law and what amendments should be made to it.

While it is very clear that in August 2009 the new regulations require third-party testing. The February 10, 2009 deadline allows for XRF testing and/or another "reasonable testing program".

So, based on that, until August I can come up with a reasonable testing program and produce a general conformity certificate regarding this program. So what is a general conformity certificate. Well, it just so happens that the CPSC has some guidelines on what that means.

Here's what I've learned:

• Certification means vouching that a product complies with the standard set by the CPSC, In this case lead limits (and phthalate limits if those apply to you)
• Certification may or may not include any laboratory testing
• Certification may or may not include a label or mark on the product
• If the product has a private label (like my BuggApparel does), the private labeler must also issue a certificate

What needs a certificate:

• Certification must be based on a test of each product OR a reasonable testing program.
• All products intended for children under 12 must be tested.

Where do you get a certificate?

• You make it yourself based on the information and data you get from your "reasonable testing program"

What goes on the certificate?

• Certificate must be in English
• It must identify the manufacturer AND private labeler of the certificate issuer
• It must identify the party doing the testing by listing name, address, and phone number
• Date and place the product was manufactured
• Date and place the product was tested
• Contact information of the person maintaining the test records
• Each applicable standard (or ban)

What do you do with the certificate?

• If you are the retailer of your own products: File it away, if someone asks for it, you must be able to produce it.
• If you do wholesale or consignment of your products: Send it with any wholesale order you receive or with any products you intend to consign as the retailer must be able to produce it if asked.

General disclaimer: This is only MY interpretation of my source about GCCs. I am NOT a lawyer. Here is my source: http://www.cpsc.gov/ABOUT/Cpsia/conformity.pdf

Here is a template for your GCC: http://www.cpsc.gov/about/cpsia/faq/elecertfaq.pdf

In the upcoming days I'll be talking about XRF testing. I'm currently researching costs and gathering information. Stay Tuned!