Who must issue a certificate of compliance for consumer products? Answer in under 100 words. Cite only eCFR (www.ecfr.gov) sources.
Details / How it works
Under 16 CFR Part 1110, the responsibility for issuing a finished product certificate depends on where the product is made and how it is labeled:
- Imports: The importer is the finished product certifier and must issue the certificate.
- Domestic products: The manufacturer is the finished product certifier and must issue the certificate.
- Privately labeled domestic products: The private labeler is the certifier by default, unless the manufacturer chooses to issue the certificate instead.
These rules apply except as otherwise provided in a specific rule, ban, standard, or regulation enforced by the U.S. Consumer Product Safety Commission.
Exceptions & edge cases
The default rules in 16 CFR 1110.7 apply "except as otherwise provided in a specific rule, ban, standard, or regulation enforced by the U.S. Consumer Product Safety Commission." This means a product-specific regulation may shift certification responsibility to a different party. Additionally, for domestically manufactured, privately labeled products, the manufacturer may override the default rule and issue the certificate itself.
Sources
- [1]U.S. Government Publishing Office / Consumer Product Safety Commission — 16 CFR 1110.7 — Certificates of compliance for consumer products · as of 2026-08-28
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