Certificates and third party testing

The requirement

Before importing for consumption or warehousing or distributing in commerce any children’s product subject to a children’s product safety rule, every manufacturer of that product, and the private labeler if it bears a private label, shall submit sufficient samples of the product, or samples identical in all material respects to it, to a third party conformity assessment body accredited under the statute, and issue a certificate based on that testing.

Separate or combined

A manufacturer or private labeler issues either a separate certificate for each applicable children’s product safety rule or a combined certificate covering all of them, in which case each rule has to be specified. A certificate that gestures at compliance generally does not meet that description.

Private labeler is the trap

If you put your brand on a pack someone else made, the statute names you alongside the manufacturer. Buying from a supplier who tested their own bulk product does not transfer a certificate to the product you assembled and labeled.

Identical in all material respects

That phrase is what allows testing a representative sample rather than every unit, and it is also what breaks when a supplier changes plating, base metal or a colorant between lots without telling you. Change control on the supply side is part of the certificate’s validity.

What a supplier declaration is good for

Narrowing the field. A credible supplier report tells you which candidate parts are worth sending for testing and which to skip. It is evidence for your own purchasing decision, and it is not the certificate the statute asks for.

And it only applies on one side of the line

Third party testing attaches to children’s products subject to a children’s product safety rule. A findings pack sold as a component to a jeweler is not in that category, and the cost difference between the two business models is largely this paragraph.

References