TradePost Archives > October 15, 2008 > this article

Electronic certificates of conformity under consideration for consumer goods

October 9, 2008
World Trade\Interactive

The Consumer Product Safety Commission is considering the use of electronic certificates to meet the certificate of conformity requirement under the Consumer Product Safety Improvement Act of 2008 (see ST&R’s Oct. 6 advisory for more details on this requirement). The CPSC states that at recent public meetings on this new law concerns were raised about the difficulty of providing paper certificates to accompany shipping containers and products inside as well as furnishing paper certificates to each distributor or retailer. Concerns were also raised about multiple certifications for the same product.

As a result, the CPSC is seeking the following information by Oct. 29.

• specific recommendations for how certificates of conformity can be made available to the CPSC for inspection, electronically or otherwise, taking into account the timing and cost of any such proposal

• specific recommendations for how certificates of conformity, whether electronic or paper, can accompany shipments of products such that they can be (a) available for immediate inspection for compliance and enforcement and (b) tied to specific shipments of products

• specific recommendations for how certificates of conformity should be furnished to distributors or retailers, electronically or otherwise

• specific comments or concerns regarding the provision of either a paper or electronic certificate accompanying products

• specific comments or concerns regarding multiple certifications by a foreign manufacturer, importer and/or private labeler for the same product