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Regulatory Compliance, AHFA

STURDY Act Prompts GCC Refresher Course

When the U.S. Consumer Product Safety Commission (CPSC) adopted a mandatory furniture stability standard last year, it quickly became apparent AHFA members needed a refresher course on General Certificates of Conformity – or GCCs – which confirm your products are compliant.

Furniture manufacturers and importers were introduced to GCCs in 2008 when Congress adopted the landmark Consumer Product Safety Improvement Act or CPSIA. Among other things, the CPSIA included provisions that set new lead and phthalate limits for consumer products, required new third-party testing and certification, and introduced, a searchable database of reported product hazards available to the public.

The CPSIA included stringent new requirements for “children’s products,” including third-party testing and a written Children’s Product Certificate (CPC) to provide evidence of compliance with all applicable product safety standards.

But CPSIA also required domestic manufacturers and importers of non-children’s products to provide a General Certificate of Conformity (GCC). In the home furnishings industry, these certificates are necessary for any product that is subject to a federal consumer product safety rule, or any rule, ban, standard or regulation enforced by the Commission.

Because the CPSIA introduced a new federal limit for lead in paint and surface coatings of “general use movable furniture articles,” GCCs should have become common paperwork kept on file for all furniture with a painted finish or surface coating, beginning in 2008.

With passage of the STURDY Act, the GCC for non-children’s clothing storage units and the CPC for children’s clothing storage units must also confirm compliance with the new stability standard.

Third-party testing is not required for non-children’s products, but compliance must be backed by a “reasonable testing program” (defined in CPSC’s Frequently Asked Questions for GCCs).

AHFA members were reminded of the GCC requirement in a presentation at last year’s Regulatory Summit in August. When that session generated numerous questions, AHFA scheduled a webinar in November to review GCC basics. Finally, last month AHFA slated another webinar, this one to explain the CPSC’s plan to require importers to file their GCC’s electronically beginning in 2025.

Some of the most frequently asked questions at these three forums included:

Who issues the GCC? Per 16 CFR § 1110.7, the domestic manufacturer or importer is responsible for drafting and issuing the GCC for each product subject to product safety rules or federal standards. When an importer issues the certificate, the importer does not need to be located within the United States, nor do they need to list a U.S.-based address. The domestic manufacturer or importer is always legally responsible for issuing the GCC, even if a third-party laboratory, or another third party, drafts or assists with drafting the GCC.

Which furniture products require a GCC?

Any furniture that has a surface coating or painted finish requires a GCC confirming compliance with the lead in paint and surface coatings limit (16 CFR Part 1303). All clothing storage units covered by the STURDY Act must have a GCC confirming compliance with the stability standard (16 CFR Part 1261). (Both citations can be on the same GCC.)

Do I have to test general-use furniture at a third-party, CPSC-accepted laboratory?

Unlike children’s products, general use products do not require third-party testing by a CPSC-accepted laboratory. Third-party testing by a non-CPSC-accepted laboratory is permitted to support a GCC for general-use furniture. The manufacturer’s own “reasonable testing program” also is acceptable. The CPSC’s Frequently Asked Questions for GCCs includes a detailed explanation of what should be included in a “reasonable testing program.” AHFA advises the program be in writing; testing be performed on a regular basis (at least once a year); and re-testing occur with any design change that could impact test results.

Below are links to the two AHFA webinars on the topic of General Certificates of Conformity, as well as a link to the CPSC’s Frequently Asked Questions. AHFA member login is required to view the AHFA webinars.

General Certificates of Conformity Webinar
November 27, 2023

Understanding GCC E-Filing Requirements
March 20, 2024

Frequently Asked Questions on GCCs
U.S. Consumer Product Safety Commission