• General Certificate of Conformity (GCC): A Practical Guide

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    Bike helmet

    Planning to import products from Asia to the United States? Chances are that you must issue a General Certificate of Conformity (GCC). In this guide, we explain how this works in practice.

    Content Overview

    • What is a General Certificate of Conformity (GCC)?
    • Which products require a GCC?
    • Is a GCC required for all products?
    • What information must be included in the GCC?
    • Who issues the GCC?
    • Do I need to get the GCC approved by a third party?
    • Do I need a GCC test report?
    • Can I get the GCC from the manufacturer?
    • How much does it cost to get a GCC?
    • What’s the difference between a CPC and GCC?

    Bonus: General Certificate of Conformity (GCC) Sample

    What is a General Certificate of Conformity (GCC)?

    The GCC is a document issued by the importer or manufacturer of a certain non-children’s products.

    The GCC is essentially a statement from the importer or the manufacturer, guaranteeing (or certifying) that the product is lab tested and compliant with relevant CPSC and ASTM safety standards.

    Note that you must issue one GCC per product.

    The GCC is identical to the Children’s Product Certificate (CPC). That said, the GCC is only applicable to certain products, while the CPC is mandatory for all children’s products imported and sold in the United States.

    Which products require a GCC?

    The GCC is mandatory for bike helmets, bunk beds, mattresses and a range of other products. The U.S. Consumer Product Safety Commission (CPSC) provides a complete list of products for which a GCC must be issued.

    Here are a few examples:

    • Apparel
    • Bicycle Helmets
    • ATVs
    • Paints
    • Bunk Beds
    • Lighters
    • Mattresses
    • Bikes
    • Pool drain covers

    Is a General Certificate of Conformity (GCC) required for all products?

    No. You only need a GCC if you import or manufacture products listed on the CPSC website. For example, a GCC is not required when importing consumer electronics, watches, jewelry and a range of other products.

    Further, you’ll need to issue a Children’s Product Certificate (CPC) when importing children’s products – not a General Certificate of Conformity (GCC).

    What information must be included in the GCC?

    The CPSC provides GCC samples on their website. Here’s a summary of the information you must include when issuing a GCC:

    1. Product name and description

    2. List of applicable CPSC safety rules and ASTM standards

    3. Your company name

    4. Contact details: Mailing address, e-mail address, phone number

    5. Name of the person holding the test report

    6. Date (month, year) and place (city, country) of production

    7. Date (month, year) and place (city, country) of product testing

    8. Third-party testing company, contact person, e-mail, phone number and address

    Who issues the GCC?

    The GCC is issued by the importer or the manufacturer. However, the latter is not applicable if you’re an Amazon seller or e-commerce company importing products from Asia to sell in the United States.

    As such, you’ll likely need to create the GCC entirely on your own.

    Further, you can either keep the GCC as a digital file (e.g. PDF) or print out a hard copy.

    Do I need to get the GCC approved by a third party?

    You don’t need to file the GCC or get it approved by the CPSC or a third party. That said, the CPSC requires that your GCC should be provided as part of your product and shipping documentation.

    Here are two ways you can provide the GCC:

    Submit electronically (e.g. a PDF) if requested by the US customs or other agency
    Print a copy and send to your customs broker as part of your shipping documentation

    The main requirement is that you have a GCC ready by the time the products arrive at the port of destination. However, the GCC can be requested by the CPSC or other agency months or even years after the products have been imported and sold in the US market.

    Amazon.com is also getting stricter when it comes to verifying that listed products meet US product safety standards. As such, Amazon may also request a GCC.

    Do I need a GCC test report?

    The CPSC states that third party testing is not mandatory for non-children’s products.

    However, all products covered in the scope of the GCC must still comply with certain safety standards. As such, the lack of third party testing can be deceiving.

    For example, bike helmets must comply with the requirements outlined in Safety Standard for Bicycle Helmets – General Use. A closer look reveals that there are strict testing requirements concerning product safety:


    (a) Peripheral vision. All bicycle helmets shall allow unobstructed vision through a minimum of 105° to the left and right sides of the midsagittal plane when measured in accordance with §1203.14 of this standard.

    (b) Positional stability. No bicycle helmet shall come off of the test headform when tested in accordance with §1203.15 of this standard.

    (c) Dynamic strength of retention system. All bicycle helmets shall have a retention system that will remain intact without elongating more than 30 mm (1.2 in.) when tested in accordance with §1203.16 of this standard.


    While third-party testing may not be mandatory, product testing certainly is. That said, the average Amazon seller or e-commerce company importing products from Asia don’t have the equipment or expertise to conduct such testing.

    In practice, third party testing is, therefore ‘de facto’ mandatory when importing ‘GCC products’.

    Finally, it’s not only a matter of getting the paperwork in order. You are liable in case you import and sell unsafe products. It’s in the interest of both your business and the consumer that you do everything you can to ensure that the product is safe.

    Can I get the General Certificate of Conformity from the manufacturer?

    In theory, yes. In reality, no.

    Contract manufacturers in China, Vietnam and elsewhere in Asia are generally not even aware of the General Certificate of Conformity (GCC) requirement for certain products. Nor should they be expected to be.

    Manufacturers are not compliance experts. As such, you should not expect guidance from your supplier or take their advice on GCC and other product safety matters.

    How much does it cost to get a GCC?

    The General Certificate of Conformity (GCC) itself doesn’t cost you more than the paper it’s printed on. That said, lab testing can cost anything from a few hundred dollars and more.

    What’s the difference between a CPC and GCC?

    The General Certificate of Conformity (GCC) is only required for certain non-children’s products, such as bicycle helmets, bunk beds, and mattresses. The GCC is not required for other products.

    The Children’s Product Certificate (CPC) is mandatory when importing all types of children’s products.

    General Certificate of Conformity (GCC) Sample

    Product: T-shirt R012 (Size S, M, L)

    Standard: 16 CFR Part 1610

    Importer:

    T-Shirt Wholesale LLC
    300 Webster St, Oakland, CA
    United States
    Phone: 12345678
    email@t-shirts.com

    Holder of testing records:

    T-Shirt Wholesale LLC
    300 Webster St, Oakland, CA
    United States
    Phone: 12345678
    email@t-shirts.com

    Date and place of production:

    October 2019, Dongguan, China

    Date and place of testing:

    November 2019, Kowloon, Hong Kong S.A.R (China)

    Third-party testing company:

    Vincent Cheng
    Hong Kong Lab Tests Ltd
    89 Nathan Road, Kowloon
    Hong Kong S.A.R (China)
    Email: vincent@HK-testing.hk
    Phone: 852 123 456

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