How to Create a General Certificate of Conformity (GCC) in 7 Steps

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This guide explains how to create a General Certificate of Conformity (GCC) in 7 steps based on the standard CPSC sample structure. Each point explains what information to include, complete with examples of the different formats that can be used.

Note that this guide is written based on the assumption that you lack the capability to perform your own testing according to applicable product safety rules and must therefore use a third-party testing company.


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1. Product covered by the certificate

The standard procedure is to create a General Certificate of Conformity for each unique product model. As such, the product must be adequately identified under the first point of your GCC, and not mixed up with other products.

We normally include the following information:

  • Product name
  • Description of the product
  • Colors
  • Size
  • Other variations
  • Materials (in some cases)

As noted above, your General Certificate of Conformity doesn’t necessarily need to be limited to a single color or size. However, if you include multiple variations of the same product, then it’s essential that these are covered by the same product safety rules, manufacturing location, and date, and test reports detailed in the following parts of the GCC.

Further, the product must also be easily identifiable in the test reports supporting the GCC. In general, this means that the product name, model, SKU, and other information in the test report should match what you write under point 1 in your GCC.

Example A: Single Product

Product name: Foam Mattress Model C, White
Size: 38″ x 75″
SKU: 75C

Example A: Multiple Product Variations

Product name: Foam Mattress Model C

SKU Color Size
3875C White, Beige 38″ x 75″
6080C White, Beige 60″ x 80″
7680C White, Blue 76″ x 80″

How to Create a General Certificate of Conformity (GCC) in 7 Steps

2. List of CPSC product safety rules applicable to the product

The second, and arguably the most important, part of your General Certificate of Conformity is to list all CPSC product safety rules applicable to the product. This is the core of the document, as you only need a GCC if your product is subject to one or more CPSC product safety rules mandating its creation.

As you will likely only create a General Certificate of Conformity if that is the case, these must thus be listed.

Examples

Part 1420 – Requirements For All Terrain Vehicles

Part 1211 – Safety Standard for Automatic Residential Garage Door Operators

Part 1211 – Safety Standard for Automatic Residential Garage Door Operators

Part 1632 – Standard For the Flammability of Mattresses and Mattress Pads (Ff 4-72, Amended)

Part 1610 – Standard For the Flammability of Clothing Textiles

3. US manufacturer or importer certifying the product

The US manufacturer or importer first introducing a covered product must certify and take responsibility for the product. This entity must be identifiable using the following information:

  • US manufacturer or importer company name
  • US manufacturer or importer address
  • Phone number

Ideally, this is the same company as is specified in the test reports supporting your General Certificate of Conformity.

Note that “US manufacturer” is emphasised. As such, you cannot merely obtain a General Certificate of Conformity from a foreign manufacturer.

4. Contact info for the individual holding test result records

The individual, likely you or someone working in your company, holding the test report supporting your General Certificate of Conformity, must be identified and contactable.

This information is normally included under point 4 of the General Certificate of Conformity:

  • Name
  • E-mail
  • Address
  • Phone number

This person can be contacted in the event that a US government agency needs to review your test report. This can occur in the following scenarios:

a. Random US customs checks

b. Random product investigations

c. Investigations triggered by safety issues reported to the CPSC or other agencies

As such, the person specified must ensure that the contact details are up to date and be ready to respond to any request from the US Customs, CPSC, or other entity.

Amazon can also check your test reports, but in my experience, they tend to request the test report together with the GCC copy in the first place.

5. Manufacturing date and place

A General Certificate of Conformity can either be issued for a specific batch or time frame for multiple batches. The purpose is to ensure that your product can be linked to a specific production run. This makes it easier to identify potentially unsafe products in the event of a recall.

In most cases, the month and year are specified.

The place of manufacturing must also be specified. This is often done by indicating the city, province/state, and country. However, traceability is the key, so if you have multiple suppliers or if they offer multiple factories in the same area, you may need to be more specific than that and provide the factory address.

Example A: Single Batch GCC (General location)

Manufacturing date: June 2025

Manufacturing place: Hanoi, Vietnam

Example B: Single-Batch GCC (Specific location)

Manufacturing date: June 2025

Manufacturing place: 35 Cong Dang, Huu Bang, Thach That, Hanoi, Vietnam

Example C: Multi-Batch GCC (General location)

Manufacturing dates: June 2025, August 2025, November 2025

Manufacturing place: Hanoi, Vietnam

6. Testing date and place

As mentioned, a General Certificate of Conformity must be supported by a test report. The place and date when the relevant lab tests took place must be specified under this point. In my experience, most of our customers use the same format as the previous points.

What matters is that the General Certificate of Conformity can be linked to a specific test report.

7. Third-party testing company identification

Finally, the testing company that issued the test report must be indicated. The following is normally included:

  • Testing company name
  • Address
  • Contact person
  • Email
  • Phone

This does not have to be a CPSC-accepted laboratory. However, be aware that large testing companies like TUV Rheinland and Intertek testing companies often operate hundreds of different laboratories around the world. You need to include the contact information for the specific laboratory that performed the testing for your product, rather than their general trade name and contact details.

  • (USA & EU)

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    Sources: Our articles are written in part based on publicly available information, and our own practical experience relating to product compliance. These are some of the primary sources we use:

    • European Commission - europa.eu
    • EUR-Lex - eur-lex.europa.eu
    • European Chemicals Agency - echa.europa.eu
    • eCFR - ecfr.gov
    • U.S. Consumer Product Safety Commission - cpsc.gov
    • U.S. Federal Trade Commission - ftc.gov
    • U.S. Federal Communications Commission - fcc.gov
    • GOV.UK
    • Legislation.gov.uk
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