| The manufacturer or importer is responsible for drafting and issuing the CPC. The manufacturer or importer can draft the CPC on its own based on the test results passed by the third - party testing, without incurring any fees. |
| Importers must issue CPCs for products manufactured overseas, while US manufacturers must issue CPCs for products manufactured domestically. See 16 CFR Part 1110. |
| Even if a third - party testing laboratory or other third - party assists in drafting the CPC, the manufacturer or importer of children's products subject to children's product safety rules or other standards is always legally responsible for issuing the CPC. |
