Consumer Product Safety Improvement Act Compliance

The Consumer Product Safety Improvement Act (CPSIA) is a new law, signed in 2008, which increases the budget of the Consumer Product Safety Commission (CPSC), imposes new testing and documentation requirements, and sets new acceptable levels of several substances contained in consumer products. While the law is mostly targeted towards products intended for children 12 years of age or younger, it also affects any product subject to CPSC regulations. By February 2010, all affected products must be accompanied by certificates of conformance either in paper or electronic form stating that the product has been tested and meets appropriate standards.
Certificate Exchange Network

Complying with CPSIA

Complying with the CPSIA will be challenging for many retailers and manufacturers.  With the threat of substantial fines and/or jail sentences for companies and individuals that sell products which do not comply with the regulations, it is critical that all organizations have full visibility in to the conformity of the products they sell, and that they can produce the necessary documentation on demand. 

Recognizing these challenges, the National Association of Chain Drug Stores (NACDS) and RollStream joined forces to deliver the CPSIA Certificate Exchange Network (CEN).  The CEN is an online platform where manufacturers can post or link to existing certificates of conformity directly.  With a simple, easy-to-use browser interface, retailers can download on demand any product certificate needed to demonstrate CPSIA compliance. By providing a single location for the exchange of information, the CEN helps organizations boost efficiency and effectiveness of compliance efforts, reduce risks, and minimize costs.



Certificate Exchange Network

Certificate Exchange Network

CPSIA Frequently Asked Questions

About the Law

  • Can manufacturers provide a toll-free number for retailers to request certificates?
    The legislation states that certificates must be produced within “a reasonable time,” which is currently interpreted to be 24 hours.  This allows retailers to call a manufacturer and receive a response within one day, if that is the manufacturer’s preferred distribution method. The CEN will enable manufacturers to post certificates, URLs, testing information, or contact information, as their specific business needs dictate.

  • There are ongoing conversations about the elimination of pharmaceuticals from this requirement.  Are you familiar with this?
    The list of products covered under this legislation continues to evolve, so we recommend you consult your legal team and the latest postings at www.cpsc.gov .  Please note, however, that even if certain drugs are excluded from compliance, their packaging may still need to be certified.

  • The law requires that the certificate “accompany” the product.  How will manufacturers using the exchange network comply with this provision of the law?
    The law states that certificates may be provided electronically.  Our legal counsel has confirmed that the CEN does provide such electronic access and that this is acceptable as a means to “accompany” the product.

  • Are there laws or standards that require GTIN and lot identifiers be readily visible on the end-use consumer product packaging to make retailer searches easy to perform?
    Yes, a portion of the legislation that went in to effect in August does require code and lot identifiers on affected products.

  • Is a certificate of conformity required for each lot?
    According to the legislation, yes, certificates must be available by product and lot, although this topic continues to undergo debate.

About The Certificate Exchange Network

  • Does the CEN allow for the CPSC to have access to the certificates?
    The system is intended to provide a clearing house for retailers and manufacturers only.  As such, the CPSC will not have access to the site unless requested.  We are currently working with the CPSC to understand what, if any, access requirements they may have.

  • Could sample certificates be sent to those who haven’t started? Do you have any best practices that we can follow?
    Sample certificates are available at www.cpsc.gov.  We will offer additional information on best practices and resources during the Webinars.

  • If a certificate is NOT required for a particular product, will a supplier be able to indicate this on the CEN?
    Yes, manufacturers may choose to load product information indicating that certificates are not applicable, as a preventive measure.

  • Are Walgreens’ or any other retailers’ suppliers REQUIRED to use this service?
    Retailers, including Walgreen’s, RiteAid, CVS, and Bartell, are participating in the CEN Advisory Committee and are encouraging their suppliers to learn more about the CEN as a way to solve this challenging problem.

  • Will the CEN offer reports regarding the requests made for our products’ certificates?
    Manufacturers will receive periodic reports showing how many requests for their products have been made.

  • If a manufacturer has already signed with another software solution, what benefit does this tool offer them?
    We believe the CEN will be the primary network for the exchange of this information.  As such, there is benefit to retailers and manufacturers to establish a single industry-wide network and approach for compliance.
  • As a retailer signing onto CEN to pull certificates, do I need to know the lot or GTIN from the manufacturer to pull the correct document?
    No.  Retailers will be able to search by manufacturer, product name, and product code.

  • Can a testing facility have access to post certificates?
    A manufacturer may choose to delegate one or more of its logins to a testing facility to post on its behalf.