CPSC Certificates of Compliance and eFiling for Imported Furniture and Consumer Products: What 16 CFR Part 1110 Says

16 CFR Part 1110 is the United States Consumer Product Safety Commission rule titled “Certificates of Compliance”. It tells an importer who has to issue the certificate that accompanies a regulated consumer product, what the certificate has to state, and, for products made outside the United States, that the certificate data are filed electronically with U.S. Customs and Border Protection at entry. A buyer who imports furniture or other consumer products for sale in the United States, or who nominates the factory that will be named on the certificate, needs to read it and not only the supplier’s test report.

This article reads the part as published in the electronic Code of Federal Regulations (eCFR, Part 1110), full text as of 1 October 2026, which was the latest issue date the eCFR service offered when we read it on 14 October 2026. The part’s source note gives “90 FR 1843, Jan. 8, 2025”. We quote or closely paraphrase the text. It is a reading of the rule for procurement planning, not legal advice, and it does not decide whether any particular product needs a certificate. We did not read the Federal Register preamble, so we do not give a compliance date for eFiling; we did not read 16 CFR parts 1107 or 1109, the CBP data message guide the part refers to, or any CPSC guidance. For related rules, see our guides to the federal upholstered furniture rule, 16 CFR 1640 and lead-containing paint on furniture, 16 CFR Part 1303.

What the part covers, and what it leaves out

Section 1110.1 says the part specifies the entities that must issue certificates for finished products under section 14(a) of the Consumer Product Safety Act (CPSA), the content, form and availability a certificate must have, and that importers must file certificates electronically (“eFile”) with U.S. Customs and Border Protection (CBP) for imported finished products that are required to be certified. It also clarifies which provisions apply to component part certificates.

The same section ends with a limit that is easy to miss: “This part does not address the type or frequency of testing necessary to support a certificate.” In other words, Part 1110 is about who signs, what the certificate says and how it is made available, not about what testing a given product must pass. The testing requirements sit in the rule or standard that applies to the product, and in other parts of the CPSC regulations that the text refers to but that we did not read.

Which products must be certified

Section 1110.5 is a single sentence. Finished products “subject to a consumer product safety rule under the CPSA, or similar rule, ban, standard, or regulation under any other law enforced by the Commission, which are imported for consumption or warehousing, or are distributed in commerce, must be accompanied by a finished product certificate.”

Section 1110.3 defines a finished product as a consumer product, or a part of one, that is subject to such a rule and is “packaged, sold, or held for sale to, or for use by, consumers”. The part therefore turns on whether the product is subject to a CPSC rule, ban or standard. The text of Part 1110 does not list which furniture items are subject to one. That list is built from the individual rules, for example the clothing storage unit standard in 16 CFR Part 1261 and the paint ban in 16 CFR Part 1303.

Who issues the certificate for an imported product

Section 1110.7(a) says that, except as a specific rule provides otherwise, for a finished product manufactured outside the United States the importer, as defined in the part, is the finished product certifier and must issue a certificate that meets the part. The definition in section 1110.3 makes the importer the Importer of Record (IOR) eligible to make entry under the Tariff Act of 1930, who “may be an owner, purchaser, or authorized customs broker”. It adds that, where the IOR is a customs broker, the broker may identify the owner, purchaser or consignee who authorised the entry as the party responsible for compliance with the certificate requirements, in the data filed with CPSC.

Three further definitions bear on a project buyer. “Owner or purchaser” means a party with a financial interest in the imported goods, including the actual owner, who may be held legally responsible by CPSC for the required certificate data. “Consignee” means the party who takes custody or delivery of the goods and may be held legally responsible in the same way. The definition of importer also says that for purposes of the rule CPSC will not typically consider a consumer purchasing or receiving products for personal use or enjoyment to be the importer responsible for certification. Which of these roles your company holds on a given shipment is a contract and customs question for your adviser; the text assigns responsibility by role and not by who ordered from the factory.

The four kinds of certificate

Section 1110.3 says “certificate” generally refers to four types: General Certificates of Conformity (GCC), Children’s Product Certificates (CPC), finished product certificates, and component part certificates. A finished product certificate is the certificate required by section 1110.5, and it comes in two forms, the CPC and the GCC. A GCC is issued under section 14(a)(1) of the CPSA; a CPC is issued under section 14(a)(2) and 16 CFR part 1107. Section 1110.19 states that component part certificates are voluntary, may be relied on by a finished product certifier, and “must not be eFiled in ACE upon importation of a component part”.

What a finished product certificate must state

Section 1110.11(a) lists what each finished product certificate must contain. The items below follow the text; the wording is shortened.

• The product: at least one unique identifier from a list that includes GTIN, model number, registered number, serial number, SKU or UPC, with a description sufficient to match the product to the certificate.
• The rules: each consumer product safety rule, ban, standard or regulation to which the product is certified, identified separately.
• The certifier: name, street address, city, state or province, country or administrative region, email and telephone number of the finished product certifier.
• The records keeper: contact details of the individual maintaining the records listed in section 1110.17, which can be a position title if the position is always staffed and responsive to CPSC requests.
• Manufacture: the date (month and year at minimum) and place of manufacture, with the manufacturer’s name, address and contact details; for runs over several days, the initial date.
• Testing: the most recent date and place or places of testing for compliance, including, for each testing laboratory or other party on whose testing the certificate depends, name and contact details.
• Attestation: the certifier’s attestation. For eFiled certificates the attestation is included in the Product Registry and in the CBP data message guide; paper and electronic certificates must carry the attestation sentence the section prints, which ends by acknowledging that knowingly and willfully making a materially false statement on the certificate is a United States federal crime.

Section 1110.11(c) adds that where a certifier claims a statutory or regulatory testing exclusion, the certificate must identify the exclusion in place of the testing date and place for that rule. Section 1110.11(d) says duplicative testing is not required when one rule references or incorporates another with the same requirement, even though each rule must still be listed separately.

For the Canadian equivalent of the importer duties in this part, see our reading of the Canada Consumer Product Safety Act.

Language, format and availability

Section 1110.9(a) requires an eFiled certificate to be in English; other certificates must be in English and may also carry the same content in another language. Section 1110.13(a) says a certificate must accompany each finished product or shipment required to be certified and that “each finished product certificate must describe only one product”.

For products made outside the United States and offered for importation for consumption or warehousing, section 1110.13(a)(1) requires the certifier to eFile the section 1110.11 data elements at the time of filing the entry, or entry and entry summary if filed together, in CBP’s Automated Commercial Environment (ACE), as provided in CPSC’s message set guide. The same paragraph covers goods from a foreign trade zone and goods eligible for the de minimis exemption. For goods imported by mail, the certifier must enter the data into CPSC’s Product Registry before arrival. Section 1110.13(b) requires the certifier to furnish the certificate to each distributor or retailer, and section 1110.13(c) requires certificates to be available for inspection immediately, meaning within 24 hours, on request of CPSC or CBP.

Responsibility, helpers and records

Section 1110.15 says a certifier may maintain an electronic certificate platform, may rely on another party to test or certify component parts or finished products, and may rely on another party to enter data into the Product Registry. It then states that the certifier identified under section 1110.7 “remains legally responsible for the information in a finished product certificate, including its validity, accuracy, completeness, and availability”. A factory or broker can prepare the data; the text keeps the responsibility with the certifier.

Section 1110.17 requires certifiers to keep the certificates and the supporting records, including test results on which a GCC or CPC is based, for at least five years from the certificate creation date.

Questions to write into the supply brief

None of the following is a requirement placed on a factory by this part. They are questions an importer can settle in writing before an order is placed, so that the certificate data are available when the shipment is entered. Put each answer in the specification file.

• Certifier: who is the Importer of Record for each shipment, and has that party agreed to be named as finished product certifier on the certificate?
• Rules list: which CPSC rules, bans or standards does the importer’s adviser say apply to each item code, and are they written beside the item code?
• Identifiers: which model number, SKU or other identifier will appear on the certificate and on the carton, so that the shipment matches the data?
• Manufacture data: will the factory supply the date and place of manufacture, with its full name and address, for every production run?
• Testing data: will the factory supply the date and place of the most recent test and the name of the laboratory for each rule, in a form the certifier can copy?
• Records: who keeps the test results and certificates for the five-year period, and in what form can the records be produced within 24 hours?
• One certificate per product: how are item codes grouped so each certificate describes only one product?
• Language: is every document supplied in English?

What this reading does not cover

This article does not read the Federal Register preamble to the rule, so it does not state when eFiling became or becomes mandatory for any category of goods. It does not read CPSC’s message set guide for CBP, 16 CFR parts 1107 and 1109, the rules that apply to individual furniture items, or any enforcement provision. It does not say whether a product used in a hotel, hospital or office is a consumer product for the purposes of the CPSA; the text of Part 1110 does not answer that item by item. Confirm each point with your customs broker and legal adviser, and keep the answers with the quotation file.

For a project that sources furniture from China for United States delivery, send the same brief to every maker: the item codes, the rules your adviser lists for each, and the data the certificate needs. FBM Sourcing manages China procurement packages for overseas projects and can collect those answers from each maker before quotation.

Questions buyers ask about 16 CFR Part 1110

Who issues the certificate for furniture made in China and imported into the United States?

Section 1110.7(a) says the importer, as defined in the part, is the finished product certifier unless a specific rule provides otherwise. The importer is the Importer of Record, who may be an owner, purchaser or authorized customs broker.

Does the part say what testing a product must pass?

No. Section 1110.1 says the part does not address the type or frequency of testing necessary to support a certificate. Testing requirements come from the rule or standard that applies to the product.

What must the certificate be written in?

Section 1110.9(a) requires an eFiled certificate to be in English. Other certificates must be in English and may also carry the same content in another language.

Can the factory prepare the certificate?

A certifier may rely on another party to test or certify, or to enter data into the Product Registry, but section 1110.15 says the certifier remains legally responsible for the information in the certificate, including its validity, accuracy, completeness and availability.

How long must records be kept?

Section 1110.17 requires certifiers to maintain finished product certificates and the supporting records for at least five years from the certificate creation date.

How does FBM Sourcing support this kind of project?

We review the brief, collect comparable quotations and manage the package for the project. For suppliers you nominate, we charge a 5% commission; for products we source for you, we quote a direct price. Our own team performs one inspection after bulk production is complete and before shipment, and the client’s project team is welcome to attend.

FBM Sourcing manages the entire China procurement package for overseas construction projects. We work with Developers · General Contractors · Builders · Commercial Project Owners · Interior Design & Construction Companies · FF&E Solution Providers.