CPSC General Conformity Certificate: Requirements for Taiwan Product Exporters

A General Conformity Certificate (GCC) is a written document certifying that a consumer product subject to a CPSC-enforced standard meets all applicable rules, bans, standards and regulations. It is required by Section 14 of the Consumer Product Safety Act (CPSA) for general-use consumer products that are not primarily intended for children.

Unlike the Children's Product Certificate (CPC) which requires third-party testing, a GCC is based on a reasonable testing program — typically your own factory testing or first-party tests — unless the specific rule requires third-party testing. The importer or US domestic manufacturer is the certifier.

Any consumer product subject to a specific CPSC rule or standard requires a GCC. Common product categories for Taiwan exporters: furniture (flammability), mattresses (16 CFR Part 1633), household electrical appliances, bicycles (16 CFR Part 1512), lighters (child-resistance), fireworks, carpets and rugs (flammability), portable generators (CO emission standards) and glass doors.

Not all consumer products are subject to a CPSC mandatory standard. If no specific mandatory standard applies, no GCC is required. However, all products must still be safe under the general safety duty of CPSA Section 15.

A GCC must include: (1) Identity of the product covered. (2) Citation of the rule, ban, standard or regulation being certified. (3) Name, address and telephone number of the certifier (the importer or US manufacturer). (4) Contact information for the testing facility. (5) Date and place of manufacture. (6) Date and place of testing.

The GCC must be provided to each distributor and retailer who receives the product and must be available to CPSC on request. There is no requirement to file GCCs with CPSC in advance, but maintaining them for at least three years is recommended.

CPSC regulations require GCC certifications to be based on a reasonable testing program. CPSC has published guidance suggesting a testing program should consider: product type, nature of possible hazards, history of product-related injuries, consequences of failure to comply and testing technology available.

For most general-use products, factory QC testing combined with periodic third-party verification is sufficient. Some rules, such as the standard for lighters and fireworks, explicitly require third-party testing even for a GCC. Check the specific mandatory standard for your product.

Major US retailers (Target, Walmart, Home Depot) require suppliers to maintain a current GCC for every SKU. Many now use compliance portals (e.g. Walmart's Supplier Portal, Target's Partners Online) where GCCs must be uploaded and renewed annually or when the product changes.

Amazon requires GCC for regulated product categories. In Seller Central, the Manage Your Compliance tool will prompt for a GCC or CPC document upload when you list in regulated categories. Without it, the listing is suppressed or the product is flagged as requiring compliance documents.

A new GCC must be issued whenever: the product changes in a way that may affect compliance, the rule or standard being certified is updated and the product no longer meets the new version, or a recall or corrective action occurs. Maintain version-controlled GCCs with date stamps.

If you discover that a GCC you issued was inaccurate, notify CPSC via SaferProducts.gov and your customers. Proactive disclosure reduces penalty risk. CPSC considers good faith cooperation in penalty negotiations.