 Hello, everyone, and thank you for joining us for today's CPSC webinar. My name is Shelby Mathis. I'm the small business ombudsman here at the Consumer Product Safety Commission. And today's topic is going to be certificates of conformity, which are CPCs and GCCs, as we call them, but they're also children's product certificates and general certificates of conformity. Before we get started, I just want to go through a few housekeeping things for those of you that haven't used GoToWebinar before to attend a webinar. On the right-hand side of your screen, there are a few options or I guess benefits that I want to let you know about. The first one is questions. There is a question section on the right-hand side toolbar of your screen. If you have questions as we proceed through the webinar, please feel free to submit those. It acts almost like a GChat or an IM instant messenger. We do have somebody listening and receiving those questions, and they should be able to respond back to your questions directly. We'll also have a Q&A session at the end. I also wanted to let you know that there's a handout section on the right-hand side of your screen. That handout is actually a PDF of today's slides. As I move through the slides, you'll see that there are hyperlinks. They appear as hyperlinks on your screen, but really what they are is a picture of my screen. If you want to follow those hyperlinks as we go through the slides, you're going to need to download that PDF handout because those will have live hyperlinks. Then finally, I wanted to let you know that today's webinar is going to last 45 minutes to an hour at the end of it. We are going to format it and get it ready to post on our CPSC YouTube channel. For those of you wondering whether or not this will be available for you to view later or for you to share, the answer is yes. It will show up on our CPSC YouTube channel a few days after it might be more than a week after this webinar begins. With all that being said, quick disclaimer, I am a CPSC staff member. Today's presentation was prepared by myself as CPSC staff, and it may not necessarily reflect the views of the commission. Today's presentation agenda, the first thing, I wanted to give a broad overview of certificates because we get a lot of questions in the small business ombudsman office about certificates. So I wanted to open with a background on certificates in general, you know, why are certificates required? Where does that requirement come from? And walk through that. Then we'll go through who needs to certify, who is responsible for preparing a CPC and a GCC. We'll talk about when a certificate is required in terms of what products need a certificate to cover them. How often do you update your certificate? Is another topic that we're going to cover because it's a question that we get quite frequently. How to make your certificates available and what is acceptable in terms of availability of certificates is another topic that I will cover because we get questions on it. And then I'll go through example certificates. We'll talk about a CPC example and a GCC example, and I'll direct you to how to find those on our website. And then we'll do what I hope is fun, interactive audience polling to test your knowledge on certificates based on the content of today's webinar. I'll highlight business resources that are available to you guys through our CPSC website, through our YouTube channel and through all kinds of online tools that we have available and I'll tell you how to find those. And then we'll do a short Q&A session at the end depending on time based on questions that we've received relating to certificates. So let's get started. A background on certificates. Where does the certificate requirement originally come from? And the answer is section 14A of the Consumer Product Safety Act, otherwise known as the CPSA. The CPSA section 14A requires that consumer products be tested and certified as compliant with any applicable consumer product safety rule under the CPSA or similar rule, ban, standard or regulation enforced by the commission. And the commission there is, of course, the Consumer Product Safety Commission. Let's drill down a little bit more into section 14A and look at some of the subsections and what their requirements are. So section 14A1 of the CPSA requires certification of non-children's products based on a test of each product or a reasonable testing program. We'll talk about in later slides what a reasonable testing program means and what types of non-children's products require testing and certification. Section 14A2 of the CPSA requires certification of children's products based on testing conducted by a CPSC-accepted third-party lab. And what it means to be a CPSC-accepted third-party lab we'll talk about, how to find one we'll also talk about, and then which children's products are covered we will talk about, but I will tell you the short answer there is all of them. Section 14A and 14G of the CPSA require that you provide certificate content and availability requirements. We'll talk about what certificate content and availability requirements mean. And then section three of the CPSIA, which is the Consumer Product Safety Improvement Act, gave our agency authority to implement CPSIA and the amendments that were made by CPSIA. So we were just talking about the Consumer Product Safety Act and the Consumer Product Safety Improvement Act. It's important to note that those are statutes, those come straight from Congress. Now we're going to move to regulations, which come from the Consumer Product Safety Commission. So these are our own regulations that we have passed that deal with product testing and certification rules. And the first one is 16CFR Part 1107, which talks about testing and labeling pertaining to product certification. And the next one that is of note, and we'll talk about in further detail here today, is 16CFR Part 1109, which is the component part rule and what it means to rely on component part testing. We'll talk about that in somewhat detail because that 1109 is a pretty extensive regulation and does offer benefits to industry. 16CFR Part 1110 is the regulation that deals with Certificates of Compliance, which is really why we're here today to talk about certificates of compliance and their content and the requirements there. So more background on certificates, they are required for the import or sale of regulated consumer products in the United States. And Certificate Certify Compliance with CPSC requirements and include the following, which again we're going to go into in greater detail. This is just a bit of a background overview. Certificates include a product description, the safety regulations to which the product is certified, where and when the product was made, where and when it was tested, and who maintains the testing records. And we'll go into some pretty serious detail with examples later in the presentation today. Important to remember that certificates must be legible and they need to be in English as well. So who must have a certificate? The short answer here is domestic manufacturers and importers are required to have certificates and why is that? Well, our agency has put out guidance that states the following. The manufacturer or importer of a product subject to product safety requirements is always legally responsible for issuing a children's product certificate, also known as a CPC, or a general certificate of conformity, a GCC, even if a third party testing laboratory or another third party provides assistance in drafting the CPC or the GCC. And the important thing to note here is that it's ultimately the manufacturer or importer's responsibility. You can have assistance, we'll talk about that in a bit, but it's ultimately your responsibility and it's going to be your information that's included in section three, which talks about the manufacturers and importer's contact information on those certificates. So now that we've gotten the background and we know who needs to create a CPC or a GCC, let's talk about what products require a CPC and we'll start on the children's product side because this one is probably more expansive in terms of its impact and we probably get the most questions about children's product certificates. So the short answer for products requiring a CPC is that all children's products require one. And what is a children's product? A children's product is defined as a product designed or primarily intended for children 12 years of age or younger. So examples of children's products that require CPCs. Durable infant or toddler products, which is an expansive category that includes many, many types of products. Childcare articles, which are defined as products that facilitate sleeping, feeding, sucking or teething for children under age three. Children's toys, children's clothing, children's bicycles, children's jewelry, and many others. This is just some examples. You'll notice the things that all of these have in common is that they begin with the word children or child or infant or toddler. In short, if the product is for 12 years of age or younger and that's its primary intent and it's marketed and designed for that purpose for 12 and under, then it's a children's product and you need a children's product certificate. A useful link is provided at the bottom of the screen and it's our rules requiring third party testing and a children's product certificate page, which you can follow for more information. Again, remember from our intro at the beginning, it appears on your screen as a hyperlink, but you're really looking at a picture of my screen. So if you want to follow that hyperlink, you need to click on the handout section on the right-hand side toolbar and download the PDF of today's slides to follow that hyperlink. Children's product testing requirements. In general, children's products need to be tested at a CPSC accepted third party laboratory and they need to be tested to applicable CPSC product safety requirements. There are some exceptions to this rule that apply to qualifying registered small batch manufacturers. And what does it mean to be a small batch manufacturer? Well, I'm glad you asked because there's more information available on our website at the address on your screen. Apologies. And again, if you want to follow that hyperlink, you need to click on the handout on the right-hand side. To find a CPSC accepted lab, you can visit our new lab search page available at cpsc.gov forward slash lab search. And this is a page we've recently redone so that it's more user-friendly. You can now keyword search such as for flammability China to find labs located in China that can conduct flammability testing. You also have the ability to narrow your scope by region, which could be city and state or country, and you can narrow your search by testing scope such as for lead paint testing or for flammability testing. So what types of products require a CPC? I'm not going to go through and read every single bullet that appears on the screen. I will give you guys a second to read it because the list is pretty extensive. Important to note here is that there are certain products that are non-children's products that such as hairdryers, seasonal holiday lights, extension cords, which fall under 15 J of the Consumer Product Safety Act or the CPSA. And then there are also products, also non-children's products that are covered under the Federal Hazardous Substances Act, the FHSA, that do not require a GCC. So if you are seeing a general use non-children's product listed on the screen, it means that there is either a regulation, a statute, a ban, or some other standard that applies to that product and it would require a GCC. But for products that are 15 J rule ones or FHSA ones, they would not require a GCC. And just like for children's products, we have a rules requiring a GCC page, which is available via hyperlink at the bottom of your page. Again, you need to download the handout of the slides and PDF to be able to follow that link. But the rules requiring a GCC page has an extensive chart of non-children's products that require a GCC. So now that we've talked about the types of children's products that require a CPC and the types of non-children's or general use products that require a GCC, when is a product not required? I'm sorry, when is a certificate not required? Certificate is not required if there is no product safety rule, standard, or ban that applies to that product. Certificates are not required if the product is subject to a rule under 15 J of the CPSA. We talked about a few of those a second ago. Another example is draw strings on children's upper outerwear, that is a 15 J rule. We mentioned previously, or I mentioned previously, immersion protection on handheld hair dryers as a 15 J rule. Those do not require a certificate. Also products that are not imported for consumption or warehousing or are not distributed in commerce. Those would also not need a certificate. So what are some examples there? Products that are bound for a foreign trade zone. Products that are imported as samples only. Products that are imported or manufactured as a trade show exhibit, just as a demo or a display for a trade show to let people know about your product. More component parts that are not for individual sale. But please keep in mind once these things transition from a sample or an exhibit or a component part to a finished product bound for commerce, it is possible depending on the product that a certificate would be required then. So a very frequent question that we get in our office is, when do I need to create a certificate? How long is it good for? Does it expire? So this question, the answer to it is really based on testing intervals. So I, those of you that really know me know that I love to create charts, so I created a nice chart on your screen that is broken into two main columns, which is CPCs for children's products and GCCs for non-children's products. And let's first talk about periodic testing requirements. So for products that are in continuous production, these are products that are being manufactured throughout the year on some sort of interval. We're not talking about batch production where you make and import one group of things in bulk. We're talking about things that are in continuous production throughout the year, they are subject to periodic testing requirements. And that periodic testing for children's products is required at a CPSC accepted lab at one of the following. One-year intervals, if you have a periodic testing plan, which the majority of children's products are going to fall into the one-year interval testing requirement here for periodic testing. If you have a production testing plan in place for your children's product, you would be required to test at two-year intervals at CPSC accepted labs or, and this is a very small group here for children's products, at three-year intervals if you are conducting continued testing using an accredited lab that meets the ISO-IEC standard shown on your screen. So the majority of children's products will need testing if they're in continuous production at one-year intervals, but there are a two-year or three-year interval testing option. When you retest, you need to update your certificate. For items that are non-children's products that are in continuous production, for GCCs, importers and importers should follow a reasonable testing program, and if applicable, the rule that applies to their general use product, again, not all general use products, have mandatory standards or regulations associated with them. Our CPSC staff has provided guidance on a reasonable testing program and what might form part of a reasonable testing program in the notice of proposed rulemaking on 16 CFR Part 1107 subpart B that is available via that hyperlink on your screen. It will direct you to a federal register notice, and you'll need to focus on subpart B of the federal register notice, again, that hyperlink available via the handout for download on the right-hand side of your screen of the PDF of today's slides. So we talked about products in continuous production. What happens if you make a material change on those products? What is a material change? I guess, first of all, we should define a material change is any change that could affect compliance? For children's products, if you make a material change, you must retest the component material or the finished product as applicable upon a material change, and you'll need to update your certificate then. For general use or non-children's products, retesting upon a material change represents industry best practice, and of course, upon retesting, you would update your certificate. Please note, you must ensure that your consumer product complies with applicable requirements at all times, regardless of testing intervals that are shown on the screen or the testing intervals that you're doing that might be more frequent than what is shown on your screen. So I mentioned component part testing a little earlier, and I mentioned it because it is a voluntary way to reduce burden. Component part testing is covered under our Regulation 16 CFR Part 1109 and basically allows a finished product manufacturer to purchase a component from a supplier who voluntarily tests its products, such as a paint supplier, and it allows the manufacturer or the finished product manufacturer to rely on a component part manufacturer's certification that the product is compliant as long as you are exercising due care in your reliance upon that component part certificate or component part testing results. So the concept of what it means to exercise due care is flexible, and it's going to vary depending upon the circumstances and the industry in question, but this is a potential way to avoid retesting a product if a component part of it has already been tested by the supplier that provided you that component part. So for example, on component part testing, depending upon the industry and the circumstances, the exercise of due care may include the following. Asking questions about testing and sampling procedures. Requesting written test procedures. Ensuring the supplier's third party laboratory is CPSC accepted. Spot checking a supplier's test results. Visiting a supplier's factory or third party lab. Or agreeing contractually on testing and record keeping. An important thing to note here, if you are relying on component part testing, you're going to want to make sure that you document your exercise of due care. Because maintaining those records is going to ensure that if something ever happens with your product, that you're able to go to the CPSC and say, I was exercising due care, here's my record of doing so. So when do certificates need to be made available? This applies to both CPCs and GCCs. The important terms are shown in bold on your screen. First, they must be created before importing for consumption or warehousing or distributing products in commerce. Certificates must also accompany each product or shipment of products covered by the same certificate. A copy of the certificate must be furnished to each distributor or retailer of the product. And there is no requirement to provide the certificates to your ultimate consumer or end customer. A copy of the certificate must also be made available to the CPSC and Customs and Border Protection upon request. Electronic certificates are another topic that we receive many questions on. And our commission, by rule, allows certificates in electronic form. The caveat here being, they must be created before the shipment or first distribution within the United States. And that's per our regulation 16 CFR 1110.13. And you must be able to verify on the electronic certificate, either a date of creation or last modification. And again, that's from our reg 1110.13 subsection B. So all of this was leading up to what goes in a certificate. The answer is there are seven elements in both a children's product certificate and a general certificate of conformity. And we'll go through each of these kind of as an overview. And then we're going to go through some samples and talk about what it means to meet each of these elemental requirements. The first one is a description of the product covered by the certificate. That's in section one. And one of the most important things to include on your certificate is what product is covered by that certificate. Section number two, this is probably the medias to most voluminous part of the certificate, which is the citations to each CPSC safety rule to which you're certifying compliance. And we'll go through some samples so you can see what that means. Number three is importer and domestic manufacturer contact information. Number four, contact information for a person maintaining test records. Number five is the date and place of manufacture of the product that the certificate is covering. Number six is the location of testing and the date of test on which the certification is based. And number seven is the contact info of the testing lab that conducted the testing for you on which your certificate is based. So a few things to remember on certificates. There are many requirements in which you need to ensure compliance, but they don't need to appear in your certificate. So some examples are permanent tracking information, which is required on all children's products on both the product and the packaging. You have to make sure that you have permanent tracking information on your products, but you don't need to certify that or even reference it on your certificate that you've met that requirement. Registration cards, this applies to all durable infant or toddler products. They all require a registration card to be included with them. You don't have to certify that you have met the registration card requirement, you just have to meet the registration card requirement. Instructional literature and safety labeling requirements, which vary by product. These requirements are generally found in ASTM standards, specifically on durables, that's the ones that come immediately to mind, that have been incorporated into a mandatory standard. Of course you have to meet the instructional literature and safety labeling requirements for your product, but you don't have to certify that in a certificate. You just have to make sure that you're ensuring compliance. And then lastly on product certification, there are certain products that require on product certification. Again, you have to make sure that on product certification is there, but you don't have to include that information in your certificate. So let's break each of the seven sections of certificates down and go through what are some compliant examples of meeting each of these sections. Section number one, identification of the product covered by the certificate. So what the CPSC is looking for here is a description of the product covered by the certification in enough detail to match the certificate to each product it covers and no others. So there are sample CPCs and GCCs on our website and I'll tell you guys how to find those once we go through these samples. But for purposes of today's webinar, we're gonna go through two samples. One is a CPC on a children's toy and one is a GCC on an adult mattress. For the CPC on the children's toy, for the ID of the product here in section one, we've got a children's toy shape sorter, the model is entitled show and tell. We've got a UPC or a SKU of some sort there and then the colors of models that are covered by the certificate, which is blue, red and yellow. So that would meet the requirement of fully identifying the product and the certificate in section one. For our GCC sample of the adult mattress available on our website, a Lux mattress model, number 456 and 789. Those are two different models of mattresses available in king and queen size. That would meet the section one requirements for a GCC and again, these are straight off of our website for the sample CPC and GCC. So I warned you section number two was the meteor part of a certificate. So let's talk about section two. In this section, you're gonna cite to each CPSC product safety rule, which the product is being certified. And you're gonna need to list them specifically as they apply to your product. So for the CPC sample for children's toys, a children's toy. In this case, we know it is a fictional shaped sorter and it's meant for younger children. It comes in multiple colors because we know that from the product description. So the CPSC rules that are going to apply appear in bullets on your screen. And you would need to include this in section two of your certificate. The first is the ban on total leg content in excess of 100 parts per million. That's 15 USC 1278 A, that's a congressional statute. Because we know there are three different colors of the shaped sorter, and we're assuming that it's painted to generate those colors. The ban of leg containing paint and certain consumer products bearing leg containing paint for toys and other articles intended for children. Or 16 CFR part 1303 is listed in the second bullet because it would apply to the shaped sorter. Because the product is meant for children under three, shaped sorter is in general for a very young child. Small part, the small parts ban for toys and other articles is also included in the list, which is 16 CFR part 1501. All children's toys require certification to the US toy standard, which is ASTM F963-17. In this case, we're specifically interested in the heavy elements and accessible toy substrate materials. So that section needs to be specifically called out on your certificate. So we've referenced it there. The toy itself would need to meet all the requirements of ASTM F963-17. And then lastly, if the shaped sorter included plastics, which we've assumed for purposes of example here that it does. The prohibition of children's toys and childcare articles containing specified phthalates would also need to be listed as a CPSC reg that applies in that 16 CFR part 1307, which is our reg on phthalates. For the adult mattress, a much simpler list. There are two tests that apply to all mattresses. They are 16 CFR part 1632, which is the smoldering flammability test for mattresses and mattress pads. And 16 CFR 1633, which is the open flame test for mattress sets. So a much simpler section for people to know how to complete is section three, which is the identification of the importer or domestic manufacturer that's certifying compliance of the product. Here you see you're gonna need to provide the name, full mailing address, and telephone number of the importer or domestic manufacturer that's certifying the product for the CPC sample for children's toys. We've made up a fictitious toys, toys, toys, importer. You can see a street address, a city, a state, a zip code, and a telephone number there to meet the section three requirements. For adult mattresses, you can see another made up manufacturer or importer, which is mattress safety USA importers. You see a street address, a city, a state, a zip code, and a telephone number to meet the section three requirements of the certificate. For section number four, this covers contact information for the individual maintaining records of test results. You wanna make sure to provide the name, full mailing address, email address, and telephone number of the person that's maintaining test records and supported the certification. For the sample CPC, for the children's toy, we've got Lisa Lane, again a fictitious compliance manager, add our toys, toys, toys importer. You see her name, her full mailing address, her email address, and a telephone number is there. And we have the same for fictitious Mary Smith on her adult mattress GCC sample. Mary Smith is the compliance and quality control person at mattress safety USA importers, again street address, email address, and telephone number to meet the section four requirements of her GCC. Section number five of the certificate needs to cover date and place for the product was manufactured. For the date when the product was manufactured, provide at least the month and year. If production is running continuously throughout the year, put January to December of the year that the production is running continuously. If it's only running through a certain portion of the year, put March to June of the year that the manufacturing is taking place. For the place of manufacturer, provide at least the city or administrative region, state if applicable, and country where the product was manufactured or finally assembled. And if the same manufacturer operates more than one location in the same city, provide the street address of the factory. For a CPC sample for the children's toy, we see it's being manufactured in just one month, and that's June of 2011. We've got the city, the province, and the country where it's being manufactured because the manufacturer operates only one factory, so we don't have to provide a street address. For the sample GCC for an adult mattress, production is taking place in May of 2018 in Guangzhou, China. Again, meeting the requirements of Section 5 for that GCC. For Section 6 of your certificates, you'll want to provide the date in place when the product was tested for compliance with the consumer product safety rule cited above. And when it says cited above, it's referencing Section 2 of the certificate. Section 6, we as an agency are looking for you to provide the dates of the test or the test reports on which certification is being based and the locations of the testing. So for the children's toy sample, in this case, the testing took place on two days, or at two times in 2011. In June of 2011 and August of 2011, both tests took place in Guangzhou, Guangdong Province, China. For the adult mattress, there was just testing at one time in June of 2018. In Guangzhou, China, again meeting the requirements of Section 6 of the certificates. Section 7, I know this is a busy slide. I want to go through a few things here because I wanted to combine children's product certificates and general certificates of conformity in Section 7. In Section 7, you'll need to identify any third party laboratory on whose testing the certificate depends. For the lab, you're going to need to provide the name, the full mailing address, and the telephone number of the lab. And that can usually be found at the bottom, usually at the footer of each page of a testing report. For children's product certificates only, there could be registered small batch manufacturers, again for the definition there, or what it means to be a small batch manufacturer. You can follow the hyperlink in your PDF slides. Registered small batch manufacturers who are not required to third party test their product to certain children's product safety requirements, must include their registration number provided by the CPSC in the section of the children's product certificate. So if you are making or importing children's products and you are a registered qualifying small batch manufacturer, and there is a test that you are conducting not at a third party lab, but on your own, such as to the toy standard, ASTM F963-17. Registered qualifying small batch manufacturers can test to the toy standard themselves, to certain portions of it, depending on the design of the toy. In section seven, you do not have a testing lab potentially to include the name, full mailing address, and telephone number of. So you will, as a small batch manufacturer, instead, include your registered small batch manufacturer number that you were given by the CPSC in section seven. Also for children's product certificates and small batch manufacturers, products that are manufactured by registered small batch manufacturers still need to comply with all the applicable children's product safety rules. So looking at the two sample certificates for a children's toy, the children's product certificate sample has Guangzhou quality labs. Again, a fictitious lab, you see the street address, you see city, province, and country, along with a zip code, and a telephone number there for the contact, and believe it or not, we have the same fictitious lab doing the adult mattress testing for our GCC sample to meet the requirements of section seven of the certificates. For children's products, when you're preparing a children's product certificate, and when you're looking for a CPSC accepted third party lab, you need to make sure that the CPSC accepted testing lab that you're looking for can conduct all the testing that you need to have done for your children's product. So the reason that there's an asterisk next to the CPSC sample for the children's toy is because we are assuming that that fictitious lab, Guangzhou quality labs, can conduct all the testing that was necessary on that children's toy that we listed in section two. So when looking for a testing lab, make sure they can do all the testing, they're accepted by the CPSC to do all the testing you need to have done on your product. So we've been going through two samples for a GCC and a CPC. You might be wondering, how do I find those? You can find them for the sample children's product certificates. They are available online at CPSC.gov forward slash CPC. Again, that hyperlink works from the handout slides and PDF on the right hand side of your screen. The two sample CPCs that we have available online for a children's toy, which you guys now know by heart and for children's clothing. In terms of general certificates of conformity, we have two samples available online. One is the sample GCC for a mattress again, which you guys know by heart and the GCC for adult clothing is also available at CPSC.gov forward slash GCC. All right, now let's move to what I hope will be a bit of fun. Audience polling. So I am going to go through five questions with you guys and we're going to see how much you've learned based on today's discussion. And these are actual questions that we get in our office. So if you think they're easy or if you think they're hard, you have some insight into our day to day life. So the first question we've got a nice little stuffed teddy bear here is I plan on making a stuffed toy. Do I need a CPC or a GCC for that product? So I'm going to put the question up on your screen and then if you guys will provide the answer on whether you need a GCC or a CPC or neither for that stuffed toy. And we'll give you guys a second to answer. And it looks like everybody is about done with providing answers. So I'm going to close the poll and let's see what we as a group thought the answer was there. So as a group resoundingly, everybody thought that stuffed toy needed a CPC. So let's see if you guys were correct. Great news. You guys were correct. That stuffed toy requires a CPC. And why is that? Well, stuffed toys are generally considered children's products, which are products intended primarily for children 12 and under. So you might be feeling like you really know everything about certificates, but that was just a warm up question. So let's see how you do on the next question, which is a little bit more complex. So here's the next question. I plan on importing seasonal holiday lights. Do I need a CPC or a GCC? Let's see what you guys think on this question. Your options are children's product certificate, general certificate of conformity or neither. Oh, and we have two answers that are kind of running neck and neck here on the importable or the importing of seasonal holiday lights. So I'm going to close the poll. Thank you everybody for participating and let's see what we as a group thought the answer was. And appears that there was a bit of a tie between GCC and CPCs or sorry, GCCs and neither on the seasonal holiday lights, 41% thought that a general certificate of conformity is needed and 54% thought neither one was needed. Let's see what the right answer is. And the majority was correct for seasonal holiday lights. You don't need a certificate at all. And why is that? Because seasonal holiday lights are covered under 15 J of the Consumer Product Safety Act or the CPSA and that is not a consumer product safety rule and does not trigger any testing or certification requirements under 14 A of the Consumer Product Safety Act. So if you thought that question was challenging, we're going to move on to the next question, which is, I plan on importing hard hats that are not primarily for children. Do I need a CPC or a GCC? And if you guys will tell me whether you think those adult hard hats need a CPC, a GCC or neither, we'll see what the group thinks. All right, and it looks like just about everybody has voted. Thank you everybody for participating. I'm going to close this out and we're going to see as a group what we thought was needed for those adult hard hats. It looks like 63% thought that a general certificate of conformity was needed and 36% thought that neither a children's product certificate or a general certificate of conformity was needed. Let's see if the majority thinking a GCC was needed or correct. The answer here is actually neither. You don't need a certificate at all. And why is that? Well, these are adult hard hats. So they would be general use products, which might mean they need a GCC, but only certain general use non-children's products require a GCC. And again, here we have a very handy link to the rules requiring a GCC site for more information. And you can get that off the PDF download of the slides that are available on the handout section of the right hand side of your screen. Okay, so let's see how we do on this next question. I am an importer of toy water guns for children. Can I just use my manufacturer's testing report as my children's product certificate? So let's see what you guys think the answer is to this question. So can I rely on my manufacturer's testing report as my children for my children's water gun CPC? Answer yes, no, or it depends. All right. And it looks like everybody pretty much has participated. I'm going to see what we as a group thought the answer was to whether or not you can rely on a testing report as your children's product certificate. So the majority thought the answer was no, although there was a pretty large group that thought the answer was it depends. Let's see what the real answer to the question is. So the answer here is no, a testing report. And I wanted to put this question in here because it's a it's a distinction that I thought needed to be drawn in this webinar. A testing report is different than a certificate. As an importer, you need to create your own children's product certificate. You can rely on the testing report from a manufacturer, as long as you exercise, do care. And we've talked about what that means, but you'll need to create and produce your own children's product certificate. And the way that we describe this to people who phone in is that a testing report is actually quite extensive. It's multiple pages long. It talks about how the product performed on tests that apply to it based on where you're importing it into. If, you know, if that's the United States for the children's toys, such as these toy water guns, we've already seen there's lots of tests that need to be conducted. There could be a page. There could be one page for each test in your testing reports and multiple pages long. The certificate, the children's product certificate is basically like a cover page. It's usually one, maybe two pages long at the most that just contains those seven elements. It doesn't talk about, you know, whether it read non-detect or what PPM of lead it read. It only talks about what testing was conducted and certifies that you passed. So important distinction to draw between a testing report being different than a certificate. So let's look at our last product here and see how you guys fare on this final question, which is, do I need to certify the tracking labels on my children's toy? Meet the requirements in my children's product certificate. So your options are yes, no, or it depends. And I'm going to close the poll because it looks like most folks are participating and have gotten their answers in. Thank you guys again for participating. Let's see as a group, whether you thought certifying to tracking label compliance was needed in a certificate for this children's toy. Looks like the majority thought the answer was no, although there's a pretty large group that thinks the answer is yes. So let's see and 4% said it depends, which is a very nice answer that 4% went with. So let's see what the answer is here. The answer is no. You don't need to include certification that your children's product, in this case a children's toy that cute little ride on toy meets tracking label requirements. You do need to ensure compliance with the tracking label requirements on the product and the packaging, but you don't need to include reference to the tracking label requirement in your certificate. So thank you everybody for participating in the audience polling. I'm just going to go through a few CPSC business resources and then we'll do a few quick questions at the end. So the first business resource that I want to let you guys know about is our business education pages. These are available at CPSC.gov forward slash business education. And the reason I bring this up is because they appear alphabetically on the right hand side of that business resources or business education page. And I think we're up to about 60 of these pages. So you can see them alphabetized their A, B, and C. If you are importing or making a consumer product that you believe may have a regulation associated with it, go to business education and see if there's a page that we've created for it. And if so, click on that page and it will tell you all the labeling, testing and certification requirements associated with that product. So people really like the business education pages and wanted to bring them to your attention. I also wanted to let you know about our webinars that are available on YouTube. So today's webinar is not yet on YouTube. It will go up after today's presentation is done. But our CPSC YouTube channel is available at youtube.com forward slash US CPSC. And once you get to the YouTube screen, you'll see where the red circle is. There you have to click the playlist tab, which you can see I've clicked and where it's circled that says business education. And these are 13 webinars, most of them available in English, but some available in Chinese as well, that talk about specific consumer products and what requirements apply to them. It's definitely something to check out and it's something you can refer people to as a useful resource. So the last business resource that I want to let you guys know about because I'm really excited to let you know that we have given the regulatory robot a bit of a reboot and a facelift. The new robot is available on the old robot site, which is business.CPSC.gov forward slash robot. The new robots has some enhanced functionality. One is it's going to ask you a lot fewer questions. It's going to ask you to pick which of nine categories of goods your product falls into. And then you're going to answer on average about three questions and it's going to generate an end report for you, which you can download and keep. It also generates a URL that you can share with others so they can view that report. One more nice thing is that the regulatory robot, the entire robot itself and all of its content is available in English and simplified Chinese large portions of it are also available in Spanish, Indonesian and Vietnamese. So please check out our regulatory robot and we would love to receive feedback on it, which you can submit to us via the robot itself. My email address is on your screen, along with a phone number that rings at three desk. That's the seven nine four five phone number you can follow us on Twitter at CPSC small biz. If you're wondering about future webinars, if you want to know what events we're going to be speaking at, what trade shows will be at or just how to see us and meet us face to face. You can follow us on Twitter or you can subscribe to our SBO newsletter by going to CPSC.gov forward slash email and selecting small business ombudsman updates. We send the newsletters out about monthly and we'll always tweet about webinars like this to let you know what's coming next. So last thing before I sign off, we're always impressed with the participation and the enthusiasm that we receive when we do these webinars. So thank you so much and we look forward to seeing you at our next webinar.