The Consumer Product Safety Improvement Act (“CPSIA”), enacted in 2008, represented a major overhaul of federal consumer product regulation in the United States and is mostly known for its targeting of so-called “children’s products.” Less well known is that the CPSIA also mandated that domestic manufacturers and importers, including private labelers, of all “consumer” products issue General Certifications of Conformity (“GCC”) to “accompany” each shipment of their goods, whether or not they are intended primarily for use by children.

In early 2009, the U.S. Consumer Product Safety Commission (“CPSC”) announced a stay of enforcement of the CPSIA’s then new GCC requirements and effectively halted their implementation; the stay was subsequently lifted with respect to children’s products and a few select non-children’s items, such as all-terrain vehicles. However, in a significant year-end development, the CPSC announced that, effective January 26, 2011, it is lifting its enforcement stay with regard to the application of GCC requirements to carpets and rugs, vinyl plastic film, teen and adult “wearing apparel,” and associated clothing textiles. 75 Fed. Reg. 81236. Lifting of the stay with respect to other specified categories of consumer products will continue throughout the year.