If you think you may have made a material change to your children's product after initial certification or you have been informed of a material change from your supplier or foreign manufacturer, you must have samples of the product or component part of the product tested by a third-party, CPSC-accepted laboratory. After the testing, you must issue a new CPC.
A material change is a change that the firm makes to their product's design, to the manufacturing process, or to the source of component parts for the product, which could affect the product's ability to comply with the applicable requirements.
If you think that you may have made a material change to your children's product, you must retest the product or component part of the product with the material changes. After receiving passing test results, you must issue a new CPC.
It depends. When there is a material change to a component part of a product that does not affect other component parts and does not affect the finished product's ability to comply with other applicable children's product safety regulations, then a manufacturer may issue a new CPC based upon the combination of the earlier initial certification test and the new test for the materially changed component part.
For example, if you manufacture a painted wooden toy car, and you change paint supplier(s), you need to test only the paint for compliance in order to issue a new CPC. In other words, because parts like the metal axles did not change, you do not have to retest them. If, however, the suppliers of the metal axles changed, then the whole finished product may need to be retested for compliance with requirements such as the small parts ban.
Not necessarily. After a children's product is initially tested and certified, the frequency with which subsequent shipments need to be tested depends upon various factors. Firms must have a high degree of assurance that the children's products it manufactured after the initial test and issuance of a CPC, or since the previous periodic testing was conducted, continue to comply with the applicable children's product safety regulations. Firms need to be aware of all material changes that may require retesting after a material change.
Yes. The manufacturer, the manufacturing facility, its equipment, and its processes and process controls may all impact the likelihood of the product's compliance (or lack thereof) with the applicable consumer product safety regulation(s) for that product; therefore, the product would require retesting and recertification.