By Jamie Venable
Last updated on July 29, 2026
New CPSC General Certificate of Conformity (GCC) Requirements for Imported Products
As of July 8, 2026, companies importing finished products that require a General Certificate of Conformity (GCC) must comply with new Consumer Product Safety Commission (CPSC) e-filing requirements. While the rule does not change which products require a GCC, it changes:
- How and when GCC information must be submitted for imported products; and
- Adds new certificate content requirements
Background
- A GCC is required for finished general use products intended for the U.S. market, that are subject to an applicable CPSC rule, ban, standard, or regulation.
- Through issuance of a GCC, manufacturers and importers are required to certify product compliance with such rules, bans, standards, or regulations.
- GCCs must be based on test results or a written reasonable testing program.
- For privately labeled U.S.-manufactured products, the private labeler is the certifier unless the manufacturer issues the GCC.
- GCC requirements must be evaluated on a product-by-product basis. There is no “one size fits all” determination.
- CPSC’s table of regulations, standards, and bans may be used to assist in determining whether a GCC is required for a specific product.
- Check the table for presence of the respective chemical/substance and product category, and review the referenced citations.
What Is Changing
For imported products that are subject to GCC requirements:
- GCC information must be e-filed in U.S. Customs & Border Protection’s Automated Commercial Environment (ACE) at the time of entry.
- New E-filing requirement does not apply to U.S.-based manufacturers.
For all products (both domestic and imported) that are subject to GCC requirements:
- Each GCC must:
- Describe only one product
- Include new elements, in addition to all information required under the previous version of the regulations
- Records must be retained for 5 years (previously a suggested 3-year retention period)
What Remains Unchanged
The new rule does not
- Change the criteria for determining whether a product requires a GCC
- Create new testing requirements
For all products requiring a GCC (domestic and imported):
- A GCC must continue to accompany each product or shipment.
- GCCs must continue to be provided to downstream distributors and retailers.
- GCCs must be provided to the CPSC within 24 hours upon request.
Information required on a GCC
- Identity of the product (e.g., product name)
- At least one of the following unique identifiers: new
- Global trade item number (GTIN)
- Model number
- Registered number
- Serial number
- Stock keeping number (SKU)
- Universal product code (UPC)
- Alternate identifier
- Sufficient description to match the product to the certificate new
- Each consumer product safety rule, ban, standard, or regulation enforced by CPSC, to which the product is being certified
- Certifier Information
- Name
- Street address, city, state/province, country
- Email address new
- Phone number
- Contact information for the individual maintaining records on behalf of the certifier
- Individual’s name
- Street address, city, state/province, country
- Email address new
- Phone number
- Manufacture date
- Initial manufacture date (if manufacturing spans multiple days) new
- Manufacturer information, where the finished product was manufactured, produced, or assembled
- Name
- Street address, city, state, country
- Email address new
- Phone number new
- Place where testing was conducted
- Name
- Street address, city, state, country
- Email address new
- Phone number new
- Most recent test date new
- Identification of any claimed statutory/regulatory testing exclusion, in lieu of the date and place where testing was conducted, if applicable new
- Prescribed attestation statement set forth in 16 CFR 1110.11(a)(7) new
Navigating GCC Requirements with SRC
Stay ahead of evolving GCC requirements with support from SRC. Our experts provide consulting guidance to help clients evaluate product specific requirements, determine whether a GCC is required, and prepare GCCs.
