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Download Avery Dennison compliance certificates
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Children's Product Definition
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Children’s Product Certificate
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Third-Party Testing
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General Certificate of Conformity
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Testing and Labeling Pertaining to Product Certification, Final Rule
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Proposed Rule on Testing and Labeling Pertaining to Product Certification

Testing and Certification

CPSIA §102

 

Manufacturers of children’s products subject to a CPSC standard must issue a certificate of conformity based on third-party testing by an accredited independent testing laboratory.

Manufacturers of non-children’s products subject to a CPSC standard must issue a certificate based on either a test of each product, or a reasonable testing program.

  • CPSC has decided that products that require labeling under the Federal Hazardous Substances Act (FHSA) or labeling rules will not require certification.
  • The general certificates of conformity are required for special categories of products that are not likely to be Avery Dennison products (e.g., all terrain vehicles, bicycles, bunk beds, carpets, fireworks, lawnmowers, and others).

Each certificate of conformity must specify:

  • the manufacturer or importer issuing the certificate and any third party on whose testing the certificate and any third party on whose testing the certificate depends, by name, address and phone;
  • each applicable standard, ban, etc.;
  • the date and place where the product was manufactured and date and place of testing; and
  • contact information for person maintaining test records.

Availability of certificates

  • Certificates must accompany each product or shipment of products covered by the same certificate.
  • A copy of the certificate must be furnished to each distributor or retailer of the product.  Electronic form is acceptable, but the certificate must be readily accessible from information on the product.
  • A copy of the certificate must be made available to the Commission and Customs upon request.

Manufacturers and private labelers may indicate on the product label: Meets CPSC Safety Requirements when the manufacturer or private labeler has met certification requirements.  Regulations specify the size and font of the label.

Resonable Testing Program

 

For products that are not children’s products, but are subject to a CPSC standard, a manufacturer or importer must provide a certification of compliance based on a reasonable testing program. A reasonable testing program provides a high degree of assurance that the consumer products covered by the program will comply with applicable rules, bans, standards, or regulations.

A high degree of assurance means an evidence-based demonstration of consistent performance of a product regarding compliance based on knowledge of a product and its manufacture.

A reasonable testing program must consist of the following elements:

  • Product specification, with a separate specification for each manufacturing site.
  • Certification tests, conducted on samples of the product that are identical to the finished product in all material respects.
  • Production testing plan, describing tests to be performed and frequency of testing.
  • Remedial action plan, describing steps to be taken when a sample fails.
  • Recordkeeping related to all of the above.

 

The materials available and information provided at the Avery Dennison ADvantage: Complete Compliance site are for informational purposes only and not for the purpose of providing legal advice.