---
title: "Who must issue a certificate of compliance for consumer products? Answer in under 100 words. Cite only eCFR (www.ecfr.gov) sources."
canonical: https://www.m-i-n-d.ai/minds/product-safety/consumer-product-certificates-compliance
jurisdiction: "US Federal"
last_verified: 2026-08-28
license: CC BY 4.0 — https://creativecommons.org/licenses/by/4.0/
attribution: "Source: MIND (m-i-n-d.ai)"
---

# Who must issue a certificate of compliance for consumer products? Answer in under 100 words. Cite only eCFR (www.ecfr.gov) sources.

Under 16 CFR 1110.7, the importer is the finished product certifier for products manufactured outside the United States, while the manufacturer is the certifier for products made domestically; if a domestic product is privately labeled, the private labeler must issue the certificate unless the manufacturer opts to do so. The certificate must meet the requirements of 16 CFR Part 1110, including those set forth in § 1110.5.

## 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 · https://www.ecfr.gov/current/title-16/section-1110.7 · as of 2026-08-28