In accordance with the requirements of the Consumer Product Safety Improvement Act (CPSIA) 2008, the Consumer Product Safety Commission (CPSC) has defined the criteria for continued monitoring of production activities for manufacturers, in order to ensure compliance of children’s products over time. In parallel, the CPSC has defined the requirements for relying on component parts testing / certification for issuing certificates of conformity of the finished products.

These two rules have been published in the Federal Register on November 8, 2011, and they’re respectively named as “periodic testing”, addressed to children’s products, and “component part testing”, addressed to any product which is subject to any CPSC regulation (cosmetics, fabrics, food…).

• The periodic testing rule requires children's products be sent to an accredited third party testing laboratory "periodically" to confirm compliance with CPSC regulations. Samples selected for periodic testing shall be representative of the production lot. This rule will be effective since Feb 8 2013.
• The component part testing rule provides conditions and requirements for relying on component part (as an alternative to final product) testing or certification, or another party’s finished product testing or certification, to meet testing and certification requirements, as long as traceability and documentation requirements are satisfied. This rule will be effective since Dec 8 2011, so that it can be used for compliance with third party testing requirements, including lead substrate testing.

At the moment, the CPSC placed the Reasonable Testing Program for non-children’s products (required according to CPSIA 2008) on reserve. A RTP is still required by CPSIA to certify non-children’s products even though requirements have not been defined in the Final Rule. As long as the CPSC doesn’t define the requirements of a RTP, a certifier may use the procedures in the proposed rule, or reference a CPSC guidance document issued on 2009.

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