GCC vs CPC: What’s the Difference?
Products entering the United States must comply with applicable consumer product safety regulations before they can be legally imported and sold. Two of the most common compliance documents required by the U.S. Consumer Product Safety Commission (CPSC) are the General Certificate of Conformity (GCC) and the Children’s Product Certificate (CPC).
Although both certificates demonstrate that a product complies with applicable safety requirements, they apply to different categories of products and have different testing obligations. Choosing the wrong certificate or misunderstanding the requirements can lead to customs delays, product recalls, enforcement actions, or rejected shipments.
Understanding the differences between GCC and CPC helps manufacturers, importers, and private label brands ensure their products meet U.S. regulatory requirements before entering the market.
What is a GCC?
A General Certificate of Conformity (GCC) is a document certifying that a general-use consumer product complies with all applicable consumer product safety rules enforced by the CPSC.
The certificate is issued by the manufacturer or importer based on reasonable testing, certification programs, or other evidence demonstrating compliance with applicable regulations.
A GCC does not apply to children’s products. Instead, it is intended for products designed for general consumers that are subject to one or more CPSC safety rules.
Examples of products that may require a GCC include:
- Furniture
- Mattresses
- Bicycle helmets
- Household appliances
- Lighters
- Consumer electronics subject to CPSC regulations
- Sporting goods
- General household products
The specific certification requirements depend on the regulations applicable to each product.
What is a CPC?
A Children’s Product Certificate (CPC) certifies that a children’s product complies with all applicable federal safety requirements.
Under the Consumer Product Safety Improvement Act (CPSIA), children’s products are generally defined as products primarily intended for children 12 years of age or younger.
Unlike a GCC, a CPC must generally be supported by testing performed by a CPSC-accepted third-party laboratory when third-party testing is required by law.
Products commonly requiring a CPC include:
- Toys
- Children’s apparel
- Baby products
- Childcare articles
- Children’s furniture
- Children’s jewelry
- School supplies intended for children
- Ride-on toys
Because children’s products are subject to additional safety requirements, the certification process is generally more rigorous than that for general-use consumer products.
GCC vs CPC: Key Differences
| Feature | GCC | CPC |
| Full Name | General Certificate of Conformity | Children’s Product Certificate |
| Applies To | General-use consumer products | Children’s products |
| Intended Users | General consumers | Children 12 years of age or younger |
| Governing Authority | CPSC | CPSC |
| Supporting Testing | Based on applicable compliance requirements | Generally requires testing by a CPSC-accepted third-party laboratory where required |
| Covers CPSIA Children’s Requirements | No | Yes |
| Required Before Import | When applicable | When applicable |
Both certificates serve as declarations of compliance, but they are designed for different product categories and regulatory frameworks.
Which Products Require a GCC?
A GCC is generally required for non-children’s consumer products that are subject to one or more CPSC-enforced regulations.
Examples include:
- Furniture
- Adult bicycles
- Mattresses
- Household appliances
- Fireworks (where applicable)
- Lawn equipment
- Recreational products
- Certain electrical consumer products
The applicable regulations vary depending on the product type. Manufacturers and importers should identify all relevant federal safety rules before issuing a GCC.
Which Products Require a CPC?
A CPC applies specifically to products intended primarily for children.
Common examples include:
- Plush toys
- Plastic toys
- Wooden toys
- Baby strollers
- High chairs
- Cribs
- Children’s clothing
- Children’s sleepwear
- Baby carriers
- Children’s backpacks
- Children’s furniture
Many children’s products must also comply with additional regulations covering lead content, phthalates, small parts, flammability, mechanical safety, and labeling requirements.
GCC vs CPC Testing Requirements
One of the biggest differences between GCC and CPC is the testing requirement used to support the certificate.
GCC Testing
For products requiring a GCC, manufacturers or importers must have sufficient evidence demonstrating compliance with applicable regulations.
Depending on the applicable rule, this may include:
- Laboratory testing
- Reasonable testing programs
- Quality assurance programs
- Existing compliance documentation
- Production testing
The exact testing requirements depend on the specific product safety regulation.
CPC Testing
Children’s products generally require testing performed by a CPSC-accepted third-party laboratory before a CPC can be issued when required under applicable regulations.
Testing may include:
- Mechanical safety
- Physical hazards
- Lead content
- Phthalates
- Flammability
- Sharp points and edges
- Small parts
- Electrical safety (where applicable)
- Labeling verification
The certificate should be supported by valid laboratory reports covering all applicable federal safety requirements.
Information Included in a GCC and CPC
Although GCCs and CPCs apply to different products, they contain many similar types of information.
Typical information includes:
- Product identification
- Manufacturer information
- Importer information (if applicable)
- Date of manufacture
- Place of manufacture
- Applicable product safety regulations
- Testing laboratory information (where applicable)
- Date and location of testing
- Contact information for maintaining test records
The certificate should accurately reflect the product being imported and remain consistent with supporting documentation.
How to Determine Whether You Need a GCC or CPC
Selecting the correct certificate starts with identifying the intended user of the product.
Ask the following questions:
Is the product intended primarily for children under 12?
If yes, the product will generally require a CPC.
Is the product intended for general consumers?
If yes, the product may require a GCC, provided it falls under applicable CPSC regulations.
Which federal regulations apply?
Products may be subject to multiple safety requirements depending on their design, materials, intended use, and product category.
Reviewing applicable regulations early in product development helps avoid costly compliance issues later in the supply chain.
Common Compliance Mistakes
Many compliance issues occur because manufacturers misunderstand the difference between GCC and CPC.
Some of the most common mistakes include:
Issuing the Wrong Certificate
Using a GCC for a children’s toy or issuing a CPC for a general-use product can create regulatory problems during customs clearance or market surveillance.
Misclassifying the Product
A product marketed to children may legally be considered a children’s product even if similar products are sold for adults.
Product design, packaging, advertising, and intended use all influence product classification.
Missing Required Testing
Issuing a certificate without appropriate supporting testing may result in non-compliance if requested by regulators.
Testing should be completed before certification is issued.
Using an Unaccepted Laboratory
For children’s products requiring third-party testing, laboratories must be accepted by the CPSC for the applicable testing scope.
Failing to Update Certificates
Changes to product materials, suppliers, manufacturing locations, or applicable regulations may require updated testing and certification.
Maintaining current documentation is an important part of ongoing compliance.
Why Product Testing Matters
Both GCC and CPC rely on accurate compliance documentation supported by appropriate testing.
Professional product testing helps manufacturers and importers:
- Verify compliance before shipment
- Identify safety issues early
- Reduce customs clearance delays
- Support regulatory documentation
- Minimize product recall risks
- Improve product quality
- Demonstrate due diligence during compliance reviews
Testing also provides objective evidence supporting product certification when requested by regulators or customers.
Understanding the difference between GCC and CPC is an essential step in meeting U.S. consumer product safety requirements. While both certificates demonstrate compliance with applicable CPSC regulations, they serve different purposes based on product classification.
Frequently Asked Questions
1. Is a GCC the same as a CPC?
No. A GCC applies to general-use consumer products, while a CPC applies to children’s products intended primarily for children 12 years of age or younger.
2. Can a children’s product use a GCC instead of a CPC?
No. Children’s products subject to CPC requirements should be certified using a Children’s Product Certificate.
3. Does every consumer product need a GCC or CPC?
Not every product requires these certificates. Certification depends on whether the product is subject to applicable CPSC regulations and the specific legal requirements for that product category.
4. Who prepares the certificate?
The manufacturer or importer is generally responsible for preparing the appropriate certificate based on applicable regulations and supporting compliance documentation.
5. Is laboratory testing always required?
Testing requirements vary depending on the product and applicable regulations. For many children’s products, third-party testing by a CPSC-accepted laboratory is required before issuing a CPC.
Related Articles:
Request Free Sample Report