ComplyMyImport guide

Material changes and retesting children's products

A change to a children's product can affect compliance with one or more safety rules. Importers need a controlled process to identify changes, evaluate their effect, conduct required testing, and update certification records.

What changes should be reviewed?

Potentially relevant changes include:

• New materials, coatings, inks, or adhesives
• A different component or component supplier
• Revised dimensions, structure, or mechanical design
• A new manufacturing process or quality control
• Production at a different factory
• Changed age grading, instructions, or intended use
• A revised applicable standard or regulation

Not every change affects every requirement. The review should identify which rules may be affected and why.

Build a change-control record

Record the previous and new specifications, effective production date, affected SKUs and variants, supplier explanation, reviewer, and decision. Link photographs, bills of materials, declarations, and test plans.

If a material change affects compliance, the changed product or component may need third-party retesting for the affected rules, followed by an updated CPC based on appropriate passing results. Continuing-production periodic testing may create separate obligations.

Avoid silent evidence reuse

A common failure occurs when procurement changes a component while compliance teams continue using an older report. Connect sourcing and product records so a changed material or factory automatically triggers review before the report or certificate is reused.

Update downstream records

When evidence or certificate data changes, evaluate Product Registry versions and broker references before the next import. Do not overwrite the historical approved certificate. Create a new controlled version and communicate the correct identifiers.

ComplyMyImport keeps product changes, evidence reviews, applicability results, certificate versions, and exports auditable. Human reviewers remain responsible for the final determination.

This guide is general educational information, not legal advice.

Official source

• CPSC material change testing guidance: cpsc.gov/FAQ/Material-Change-Testing