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Last reviewed: September 2026 · Copy link

Factory change notification and retest

CPSIA compliance is tied to the tested production configuration. Factory change notifications — new paint supplier, moved molding line, added recycle content, swapped battery vendor — should trigger a compliance review and often new CPSC-accepted testing. Importers who auto-renew CPC dates without production truth risk customs, Amazon, and CPSC exposure.
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Changes that usually force retestOperationalize notifications
Run change-control audit

Changes that usually force retest

  • Material or colorant supplier change on plastics, textiles, or coatings.
  • New manufacturing site or subcontractor for critical components.
  • Design changes affecting age grade, magnets, batteries, or small parts.
  • Regulatory updates or buyer-required standard revisions.

Operationalize notifications

Require suppliers to notify in writing within 48 hours of any BOM or process change. Link PO terms to suspension of shipments until QA signs off.

Questions people ask

Can I update CPC date without retest?

Updating dates without underlying report support is falsification — refresh testing when production changes.

Does minor packaging art change matter?

Pure packaging graphics may not — but age grade or warning changes do; involve compliance review.

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