The certification program for non-children’s products was called a “Reasonable Testing Program” in CPSIA. Since the children’s product certification program did not have a specific name in that draft, the term “Reasonable Testing Program” has become a common name for any certification program encompassing children’s and general use products. However, under the regulations, a general use product specifically falls under a RTP and a children’s product falls under a “children’s product testing program” (CPTP).

The CPSC was not required to create a rule for the certification of non-children’s products such as apparel and hardgoods but CPSIA states any non-children’s product with an applicable rule, ban or standard enforced by the CPSC must be certified based on a Reasonable Testing Program. Therefore, a manufacturer not implementing a Reasonable Testing Program would not be in compliance with the certification requirements of CPSIA.

The requirements will apply to products manufactured on or after the effective date as designated in the final rule so it will not be retroactive.

No. Only general use products that require certification or a GCC require a RTP. However, it could be beneficial for your company to implement some or all of the program elements to help ensure good manufacturing procedures.

The CPSC has stated that the requirements of a RTP and CPTP would not supersede any established requirements of an existing rule, ban or standard. Your children’s sleepwear will still need to be tested in accordance with 16 CFR 1615/1616, including testing every 5,000 linear yards which can be part of the periodic testing plan, and comply with the other elements of a CPTP.

The product specification has several purposes: to differentiate the product from other consumer products; to provide identifying manufacturing information; and to list all applicable rules, bans and standards applicable to the product.

Many companies produce product specifications for goods they manufacture. If particular product specifications meet the requirements mandated by the RTP, they may be used. Otherwise, it would be necessary to supplement the company product specification with any requirements missing that are mandated by the RTP.