What does upstream certification mean?
“Upstream certification” means being allowed to use the test results of a manufacturer of supplies to certify that a product is lead-free or phthalate-free. For example, if you made a shirt and you certified that the shirt was lead-free because the fabric, thread, and button manufacturers had tested these materials and found them to be lead-free, you would be using upstream certification instead of your own testing.
It is unclear whether CPSC will allow upstream certification for CPSIA compliance. CPSIA specifically states that the manufacturer of the children’s product is responsible for getting third party testing on their finished product. Certainly it would make sense, especially for small volume manufacturers who carefully source their materials. However, it may not be permissible under CPSIA.
