What is an Amazon GCC Certificate?

A GCC (General Certificate of Conformity) is a declaration by the importer or manufacturer of certain general-use consumer products, guaranteeing (or certifying) that the product has been tested in a laboratory and complies with the relevant CPSC and ASTM safety standards. Please note that each GCC corresponds to a single product.

Who must issue the GCC?

According to 16 CFR 1110.7, unless otherwise specified by regulation, the domestic manufacturer or the importer (for products manufactured overseas) must draft and issue the GCC based on passing test results or a reasonable testing program for each product. If the importer issues the certificate, they do not need to have a physical entity or address in the U.S.

The domestic manufacturer or importer bears legal responsibility for issuing the GCC for products that comply with safety regulations, even if a third-party laboratory or other institution assists in drafting it.

Which products require a GCC?

All products subject to consumer product safety regulations, bans, standards, or other CPSC rules must be tested, certified, and issued a GCC. A list of regulations requiring testing and a GCC can be found \[here].

If the manufacturer or importer produces or imports general-use consumer products that fall under these requirements, they must issue a GCC. If the product is not covered by these requirements, a GCC is typically not needed. Additionally, cross-border e-commerce platforms such as TEMU, Amazon, etc., may require a GCC for certain categories.

Who must I provide the GCC to?

The GCC must be provided to distributors and retailers. Additionally, when requested by the CPSC or Customs, a copy of the GCC must be provided within 24 hours.

As long as the manufacturer or importer provides distributors and retailers with a reasonable means (physical or electronic) to access the certificate, the obligation to “provide” is considered fulfilled.

What if I sell directly to consumers without using retailers or distributors?

The law still requires the domestic manufacturer or importer to test and certify products sold and shipped directly to consumers. However, you do not need to provide the certificate to the consumer.

What elements must a GCC contain according to the CPSC?

The CPSC requires the GCC to contain seven essential elements:

1. Identification of the product covered by the certificate.

2. Citation to each CPSC safety rule or standard to which the product is being certified.

3. Identification of the importer or domestic manufacturer certifying compliance.

4. Contact information for the individual maintaining records of test results.

5. Date and place where the product was manufactured.

6. Date and place where the product was tested for compliance with the safety rules and standards cited.

7. Identification of any third-party laboratory on whose testing the certificate depends.

Note:The GCC and related test reports must be in English.

Can an electronic certificate replace a paper certificate?

Yes. An electronic certificate is acceptable provided that:

1. CPSC staff can reasonably access it when needed.

2. It contains the information required under section 14(g) of the CPSA.

3. It complies with the additional provisions for electronic certificates under 16 CFR 1110.13.

If I post the GCC online, do I need to update it for each batch or shipment?

It depends. If there are no material changes from one batch to the next, the same GCC may be used, but it must indicate the date range or batch information covered. The same GCC can apply to multiple batches as long as reasonable steps are taken to ensure compliance. When a new batch is placed on the market, the GCC should be updated to reflect that batch.

What is a Reasonable Testing Program?

Currently, there is no uniform regulation defining a reasonable testing program for general-use consumer products. Some specific standards apply to certain products (e.g., textile flammability, bicycle helmets, lighters). If your product is not on that list, consider these principles:

1. The testing program should provide a high degree of assurance that the product complies with safety regulations.

2. The testing program should be documented and approved by senior management.

3. The testing program should be reasonably designed based on the product’s nature, process, and supply chain risks.

Must products be tested in a CPSC-accepted third-party lab?

No. Although you may use a CPSC-accepted third-party lab, it is not mandatory for general-use products.

After testing and certification, how often must I retest?

There is no required testing frequency for general-use products. However, the product must remain compliant at all times, and the certificate must remain accurate. The CPSC recommends annual testing or testing whenever there is a significant change to the product. Major changes (e.g., changes in paint, parts, design, or process) that could affect compliance require retesting and updating the GCC.

Is testing required for every batch or shipment?

It is not mandatory. The CPSC recommends (but does not require) that businesses have a reasonable testing program to ensure ongoing compliance. If there are major changes or uncertainty about changes, it is best to test each batch or shipment.

What is a major change?

A major change refers to any change in design, manufacturing process, or component sourcing that could affect the product’s compliance, and that the manufacturer knew or should have known might have such an effect.

What should I do if I think a major change has occurred?

You should retest the product to confirm it still meets requirements. If necessary, issue a new GCC based on the new test results.

If only one component of the product has a major change, must I retest the entire product?

Not necessarily. If the change affects only that component and does not impact the compliance of other components or the overall product, you need only retest that component and update the GCC accordingly. If the change could affect the product’s overall compliance, retesting of the entire product is required.

What is periodic testing?

Periodic testing refers to testing conducted during continued production after initial certification. For children’s products, periodic testing is mandatory.

For general-use products, periodic testing is not required but may be conducted voluntarily by the company.

Can I rely on my supplier’s component tests or reasonable testing program to issue a GCC?

Yes. You can rely on component tests to meet testing requirements for general-use products, but you must:

1. Obtain copies of the test results from the supplier.

2. Confirm that the supplier’s testing program is reasonable.

3. Confirm that the components comply with applicable regulations.

4. Issue the GCC based on these confirmations.

When can I not rely on my supplier’s tests?

You cannot rely on component tests alone if they are insufficient to demonstrate that the finished product complies with regulations (e.g., a mattress requires flammability testing on the finished product). The certifier is responsible for ensuring all necessary tests have been conducted.

Need help?

China JJR provides professional and efficient one-stop gcc certification services. Please contact a China JJR compliance engineer for more information.