Recently, many exporters to the U.S. have been required to comply with GCC (General Certificate of Conformity) requirements. More importantly, the CPSC issued a final rule on January 8, 2025, mandating that from July 8, 2026, covered imported consumer products must be submitted via mandatory electronic filing (eFiling) of certificate data.

I. What is GCC?

GCC is a mandatory compliance document for non-children's consumer products in the U.S., certifying that the product meets CPSC safety requirements.

• Legal Basis: Section 14 of the Consumer Product Safety Act, 16 CFR Part 1110 (2025 revised edition)
• Key Dates: July 8, 2026 – Mandatory eFiling for most imported/domestic consumer products; January 8, 2027 – Applicable to products in foreign trade zones.
• Filing Method: Importers submit certificate data elements through the U.S. Customs ACE system before cargo arrival; the certificate document itself does not need to be uploaded.
• Penalties for Non-Compliance: Detention, seizure, heavy fines, and placement on heightened scrutiny lists.

II. Covered Products & Testing Requirements

Only general consumer products subject to CPSC safety rules require GCC. The detailed list is as follows:

III. Issuance Rules & Compliance Requirements

Issuing Entity: U.S. manufacturers or importers self-issue; third-party labs provide only test reports and do not assume certificate responsibility; importers are not required to have a U.S. address.

A compliant GCC must contain 7 elements: Product identification, applicable CPSC rules, manufacturer/importer identity, testing basis, laboratory information (if applicable), issuance date and location, contact person.

Testing Requirements: General products do not require CPSC-accredited laboratories; self-testing or reasonable testing programs are acceptable. Only 8 specific standards (e.g., bicycle helmets, apparel flammability) require specific test procedures as defined in the standards.

Retesting Requirements: No statutory frequency; recommended annually. Retesting is required when product design, process, or core components change. A single certificate may cover multiple batches if no material changes occur.

IV. Special Scenario Explanations

Cross-border direct-to-consumer (DTC) sellers: The importer is the "Importer of Record (IOR)." For small-package direct shipments, the overseas owner/seller may also be deemed the importer and is responsible for GCC and eFiling obligations.

Provision Requirements: Certificates must be provided to distributors and retailers and made available to CBP/CPSC within 24 hours upon request. Certificates do not need to be provided to individual consumers for DTC orders.

V. Distinction Between GCC, CPC, and CPSC

VI. Platform / Channel Requirements

Amazon Generally requires GCC upload for non-children's products subject to CPSC rules (e.g., mattresses, fireworks, bicycles and helmets, lead-painted products, etc.); children's products require CPC.

Walmart / Target / Macy's and other retailers Supplier access requires corresponding certificates of compliance; otherwise, products will not be listed or accepted into warehouses

 Temu / SHEIN / AliExpress and other cross-border platforms Compliance reviews are continuously tightening. Products in CPSC-regulated categories must provide GCC/test reports for listing; DTC models also apply.

U.S. Customs and Border Protection (CBP) Starting July 8, 2026, imported covered consumer products must complete eFiling electronic filing; otherwise, cargo may be detained.

CIRS Testing, a subsidiary of CIRS Group, is a professional third party testing institution. It provides full U.S. GCC services, including:

• category determination,
• compliance testing,
• certificate drafting/review, and
• eFiling filing support.

We have served 3,000+ cross-border platform merchants. If you need any assistance or have any questions, please get in touch with us via test@cirs-group.com.