*This document, which was prepared by CPSC staff, has not been reviewed or approved by and
may not necessarily represent the views of the Commission.
Request for Comments and Information*
Mandatory Third-Party Testing for Certain Children’s Products
Section 102 of the Consumer Product Safety Improvement Act
(“CPSIA”)
The Commission staff invites comments on Section 102 of the CPSIA, Mandatory Third-
Party Testing for Certain Children’s Products. The staff requests comments specifically on
third-party testing of component parts.
CPSIA section 102(a)(2) imposes testing requirements to support certificates of compliance
for “children's products'' as defined in section 235(a) of the CPSIA (to be codified at section
3(a)(2) of the Consumer Product Safety Act). Ninety days after the Commission issues those
requirements for a given product or category of products on the rolling schedule specified in
section 14(a)(3), the certificate for the product or products in question manufactured after that
date must be supported by testing performed by a third-party laboratory whose accreditation
has been accepted by the Commission absent the Commission's exercise of its authority to
extend such a deadline by an additional sixty days in certain instances. Given the schedule
for implementation of the third-party testing requirements, the staff is interested in comments
and information regarding:
• How the risk of introducing non-compliant product into the marketplace would be
affected by permitting third-party testing of the component parts of a consumer
product versus third-party testing of the finished consumer product.
• The conditions and or circumstances, if any, that should be considered in allowing
third-party testing of component parts.
• The conditions, if any, under which supplier third-party testing of raw materials or
components should be acceptable.
• Assuming all component parts are compliant, what manufacturing processes
and/or environmental conditions might introduce facto