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Last reviewed: September 2026 · Copy link
GCC testing requirements
Two testing bases under one certificate
For rules that require it, testing must be performed by a CPSC-accepted third-party laboratory and you certify based on those results — this mirrors how children’s products always work. For rules that allow it, the certifier runs a reasonable testing program: periodic testing of production samples, typically annual or per production lot, documented well enough to prove the product consistently meets the rule.
Either way, the certificate itself cites the same elements. What changes is whose lab performed the testing and how often samples are retested.
Rules that require CPSC-accepted third-party testing
- Bicycle helmets (16 CFR Part 1203).
- Mattresses and mattress sets (16 CFR Parts 1632 and 1633).
- All-terrain vehicles (16 CFR Part 1420).
- Architectural glazing materials (16 CFR Part 1201).
- Bicycles (16 CFR Part 1512) — third-party testing applies to this rule.
- Always confirm the current list with your laboratory: the CPSC updates third-party testing requirements over time.
Records worth keeping
- The test reports behind every cited rule, tied to the product version and factory they cover.
- Your reasonable testing program schedule and results, where one applies.
- Every issued certificate, kept with its test date so retesting is scheduled instead of discovered.
- As a practical rule, keep certificates and supporting reports for at least five years — marketplace and customs requests routinely arrive years after a product shipped.
Questions people ask
Does every GCC need lab testing?
Every GCC needs a testing basis for each cited rule. For some rules that basis must come from a CPSC-accepted third-party laboratory; for others a documented reasonable testing program run by the manufacturer is allowed. Your lab or compliance adviser can confirm which applies to your category.
How often must a GCC product be retested?
Where the rule sets a testing period, follow it. Where it does not, a reasonable testing program usually means testing at least annually and whenever the product, materials, or factory change.
Who can test for a GCC?
When a rule requires third-party testing, only a CPSC-accepted laboratory for that rule qualifies. For reasonable-testing-program rules, in-house or contracted testing is acceptable if it is documented and consistent.
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