Electronic Certificates of Conformity Allowed for Imported Consumer Products

(World Trade Interactive)

The Consumer Product Safety Commission has indicated that importers and manufacturers can provide electronically the certificates of conformity that will be required for all consumer products beginning November 12.

In a list of frequently asked questions posted to the agency’s Web site, the CPSC staff said its opinion is that electronic certificates can be used to satisfy the Consumer Product Safety Improvement Act so long as the CPSC has reasonable access to the certificate electronically and it contains all of the required information. In addition, with respect to the requirement that each imported and domestic shipment be “accompanied” by the certificate, the CPSC staff believes that an electronic certificate is “accompanying” a shipment if (a) the certificate is identified by a unique identifier and can be accessed via a World Wide Web URL or other electronic means and (b) the URL or other electronic means and the unique identifier are created in advance and available with the shipment. The staff also believes that the requirement to “furnish” the certificate to distributors and retailers is satisfied if those entities are provided a reasonable means to access the certificate.

The FAQ notes that the above information is an unofficial description and interpretation of various features of the CPSIA and does not replace or supersede the statutory requirements of that law. The FAQ was prepared by CPSC staff and has not been reviewed or approved by, and may not necessarily reflect the views of, the CPSC. Some FAQs may be subject to change based on CPSC action.