The CPSC press release says domestic manufacturers and importers have a choice to either test and certify the entire, final product OR test and certify each individual component.  Similarly, a domestic manufacturer can rely on certificates obtained by its parts suppliers as long as those certificates meet all specifications and the associated tests were conducted by a CPSC recognized lab.  Similarly, a retailer or seller that has  received certificates based on component testing from its suppliers can rely on them in the same way that they would a certificate based on testing of a final product.

The Federal Register notice titled “Interim Enforcement Policy on Component Testing and Certifications of Children’s Products and Other Consumer Products to the August 14, 2009 Lead Limits” includes further stipulations. The manufacturer or importer that certifies the compliance related to lead paint or lead components of a children’s product would have to ensure:

• Appropriate and sufficient samples are given to the lab and conform to related requirements.
• Each batch of paint or each component associated with the product can be traced to the specific component manufacturer.
• All test reports underlying the certification are included with the certificate.
• In the case of lead content (not paint), the components must be drawn from a random sample from the batch used to make the final product.
• All paints or components are identified with various attributes listed for each.

Among these requirements, the product manufacturer would also have to ensure paints and components that were tested and certified are not later contaminated with lead from other sources before or during the manufacturing process.

The CPSC intends to issue rules addressing various aspects of component testing, at which time the interim policy may no longer be in effect.