United States - General consumer product
US compliance requirements for general consumer product
Fallback category for consumer products that don't match a specific category. The baseline every consumer product faces: general product safety, market surveillance, chemical restrictions and US general CPSC duties.
For example: umbrella, storage box, stationery, travel mug.
Use a more specific category whenever one fits — this fallback can under-state sector rules. If the product is for children's play it is a toy (see toy category); the forChildren attribute here only adds the US CPSIA children's-product regime, because the EU/UK have no general children's-product law outside toys. Adding electronics via any attribute brings UKCA (UK) / CE (EU) marking obligations with the listed regulations. Battery products without digital circuitry may be outside FCC Part 15 — verify. GPSR requires an EU-established responsible economic operator and online-listing safety information from 13 December 2024; the UK GPSR 2005 is the GB equivalent (Northern Ireland follows the EU GPSR — verify your route to market).
Base requirements2 instruments
California law requiring businesses to give a clear and reasonable warning before knowingly and intentionally exposing anyone in California to a chemical on the state's Proposition 65 list, and prohibiting knowing discharges of listed chemicals into drinking water sources. It is a warning law, not a ban — products containing listed chemicals may still be sold if properly warned.
Key obligations
- 01Provide a clear and reasonable warning before knowingly and intentionally exposing anyone in California to a chemical listed under Proposition 65, unless the exposure is low enough to qualify for an exemption.source
- 02Do not knowingly discharge listed chemicals into sources of drinking water in California.source
- 03Track the chemical list: OEHHA maintains the list, which must be updated at least once a year and has grown to include over 800 chemicals (naturally occurring and synthetic) listed for cancer, birth defects or other reproductive harm since first publication in 1987. The current list is dated December 8, 2025.source
- 04Once a chemical is newly listed, businesses have 12 months before the warning requirement takes effect for that chemical.source
General-use consumer products need a General Certificate of Conformity (GCC) only if a CPSC rule, ban or standard applies to them, and every business in the supply chain has an ongoing duty to report potential substantial product hazards to CPSC. There is no pre-market approval: CPSC does not approve products before sale.
Key obligations
- 01Where a general-use product is subject to a consumer product safety rule (or a similar rule, ban, standard or regulation under any other CPSC-enforced statute), the domestic manufacturer or importer must certify compliance in a written General Certificate of Conformity (GCC), based on a test of each product or a reasonable testing program. The GCC and supporting information must be in English.source
- 02Only the importer (for products made outside the US) or the domestic manufacturer (for US-made products) must certify (16 CFR 1110.7). The certificate must be available to CPSC as soon as an imported shipment is available for inspection, or before a domestic product enters commerce, and must accompany the shipment and be furnished to distributors and retailers.source
- 03Section 15(b) duty to report (15 U.S.C. 2064(b)): every manufacturer, distributor and retailer who obtains information reasonably supporting the conclusion that a product fails to comply with an applicable rule or standard, contains a defect which could create a substantial product hazard, or creates an unreasonable risk of serious injury or death must immediately inform the Commission.source
- 04"Immediately" means within 24 hours of obtaining reportable information (16 CFR 1115.14(e); CPSC: "A company must report to the Commission within 24 hours of obtaining reportable information"). A firm genuinely uncertain whether information is reportable may investigate, but the investigation should not exceed 10 working days unless a longer period is demonstrably reasonable. CPSC's advice is "when in doubt, report" — no injury needs to have occurred.source
If your product also...
Extra regulations triggered by specific features
Has radio / wireless (Wi-Fi, Bluetooth, cellular, GPS, RFID/NFC)
FCC Part 15 — Intentional Radiators (Equipment Certification)
Plugs into mains power (50–1000 V AC)
OSHA Nationally Recognized Testing Laboratory (NRTL) Program — UL and other NRTL listingFCC Part 15 — Unintentional Radiators (Supplier's Declaration of Conformity)
Intended for or marketed to children (under 14)
Consumer Product Safety Improvement Act of 2008 — Children's Product Requirements
Documents you will need
Deduplicated across the regulations above
- Warning label / sign artworkNo certificate or government filing is required; compliance is demonstrated by the warning itself (label, shelf sign/tag, or website warning for internet sales) meeting the content and transmission methods of 27 CCR Article 6.source
- Written notice to retail sellersThe regulations allocate responsibility along the supply chain: manufacturers/suppliers can discharge their duty by providing a warning or a written notice to the retail seller under 27 CCR 25600.2(b) and (c); for internet purchases before January 1, 2028, a retailer is not responsible for posting an updated short-form warning online until 60 calendar days after receiving an updated warning or written notice.source
- General Certificate of Conformity (GCC)Must contain 7 elements (16 CFR 1110.11): product identification; citation to each rule certified to; identity (name, full mailing address, phone) of the certifying manufacturer or importer; contact for the custodian of test records; date and place of manufacture; date(s) and place(s) of testing; identification of any third-party laboratory relied on. Hard copy or electronic form is acceptable; electronic certificates need a unique identifier and accessible URL.source
- Records supporting certificationKeep test results/reasonable-testing-program records; CPSC suggests issuers maintain supporting test records for at least three years (note to 16 CFR 1110.11(d)). The certifying entity remains legally responsible for the accuracy and completeness of certificate information.source
- Section 15(b) reportReport to CPSC within 24 hours of obtaining reportable information. If another responsible party has already adequately informed CPSC, a firm need not re-report, but documentation demonstrating that is recommended. 16 CFR Part 1115 sets out the substantial product hazard reporting framework.source
- eFiled certificate data (imports, from 8 July 2026)Beginning July 8, 2026, importers of most regulated consumer products must electronically file (eFile) certificates of compliance with U.S. Customs and Border Protection via a Partner Government Agency Message Set.source
Frequently asked
Does a Proposition 65 warning mean the product is banned or unsafe?+
No. Prop 65 does not ban any product — it is a right-to-know law. A warning means the business believes the product can expose Californians to a listed chemical above the level where a warning is required (or the business is warning out of caution without measuring exposure).
Does CPSC approve my product before I can sell it?+
No. CPSC does not provide pre-market approvals of products. If a mandatory rule applies you must test (or run a reasonable testing program), certify with a GCC, and keep records — but you do not submit the product to CPSC for sign-off, and you must not claim a product is 'CPSC-approved'.
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