How to Get a Certificate of Conformity: Vehicles and Consumer Products

How you get a Certificate of Conformity depends entirely on what you are certifying. For vehicles, the EPA issues the certificate directly to the manufacturer, and an individual owner or importer requests a copy rather than applying for one. For consumer products, the manufacturer or importer writes and issues the certificate itself, based on testing that in some cases must come from a CPSC-accepted lab. These are two separate systems under two different agencies, and the steps below cover each.

Getting a Copy of a Vehicle Certificate of Conformity

The EPA does not issue a Certificate of Conformity to individuals. It issues one to the manufacturer for an entire class of vehicles, valid for a single model year, and every new motor vehicle sold in the United States must be covered by one.¹²³

When you need the actual document, the path splits by model year.

For model year 2003 and later, copies are free through the EPA’s Transportation and Air Quality Document Index System. Select “Certificates of Conformity” as the document type, choose the industry (for a passenger car or truck, that’s “Light-duty Vehicles and Trucks”), and search by model year, manufacturer, and model. The certificate downloads as a PDF.¹

For anything older than model year 2003, the database will not help you. Contact the EPA Imports Hotline at Imports@epa.gov or 734-214-4100 and give them the model year, manufacturer, model, and either the test group number (2001 and later light-duty vehicles) or the engine family number (pre-2001). That is the 11-character code on the emission label under the hood.¹

Importing a Vehicle That Has No U.S. Certificate of Conformity

Vehicles built for foreign markets usually are not covered. If yours is not, there is no way for you as an individual to get an EPA Certificate of Conformity issued in your name. What exists instead is a route through an Independent Commercial Importer, who modifies the vehicle to meet federal emission standards and brings it into compliance under their own authority.³⁴

Emissions are only half of the problem. Safety is a separate federal requirement enforced by NHTSA, and federal law prohibits permanently importing a motor vehicle unless it complies with applicable safety standards and was certified by its original manufacturer.⁵ A nonconforming vehicle has to go through a Registered Importer, who modifies it to meet Federal Motor Vehicle Safety Standards, and only vehicles on the NHTSA eligibility list qualify. Passing the EPA route does not satisfy NHTSA, and vice versa.

Both routes are expensive and slow. For a vehicle that was never engineered for the U.S. market, the cost of full compliance often exceeds what the import is worth.

One significant exemption changes the math. A vehicle at least 25 years old, measured from its month and year of manufacture, is exempt from Federal Motor Vehicle Safety Standards.⁶ The exemption is why the market exists for classic imports that were never sold here. It applies to NHTSA safety rules only; EPA emission requirements are a separate question and depend on the vehicle’s age and the state you plan to register it in.

One boundary worth flagging: an EU Certificate of Conformity, which European manufacturers issue for type-approval in Europe, does not satisfy U.S. requirements. If you are shipping a car from Europe, you still run the full EPA and NHTSA process.

Forms You File at the Border

Bringing a vehicle across the border means filing three forms with Customs and Border Protection at the port of entry:

EPA Form 3520-1, declaring the vehicle’s emission compliance status.⁷
NHTSA Form HS-7, declaring the vehicle’s status against Federal Motor Vehicle Safety Standards, bumper standards, and theft prevention standards.⁸
CBP Form 7501, which CBP produces when it processes your entry. This is your proof the vehicle was properly imported, and you cannot register the vehicle in a U.S. state without it.

Have your ownership documents ready before you get to the port: the original title or a certified copy, plus either a manufacturer’s letter confirming the vehicle meets EPA and DOT standards or the original compliance stickers still attached. A vehicle with both its EPA emission label under the hood and its DOT certification label on the driver’s side door jamb does not need a separate manufacturer’s letter.⁷

Issuing a Certificate of Conformity for a Consumer Product

Consumer product certification does not go through the government. Under federal law, every manufacturer or importer of a consumer product subject to a CPSC safety rule must issue a written certificate stating the product complies with the applicable rules.⁹ You write the certificate. The type depends on who the product is for.

General Certificate of Conformity

For a general-use product (anything not primarily designed for children 12 and under) covered by a CPSC safety rule, you issue a General Certificate of Conformity. The GCC must identify the product specifically enough to tie the certificate to what it covers, cite each CPSC safety rule that applies, name and give contact information for the certifier and for the person who keeps the test records, state the month and year the product was manufactured and the city and country of final assembly, and give the date and place of the compliance testing.¹⁰

Third-party lab testing is not required for general-use products. You can base the GCC on your own reasonable testing program, and the field for a testing laboratory can be marked “N/A.”⁹ The certificate must accompany the product or shipment and be provided to every distributor and retailer in your chain.

Children’s Product Certificate

If the product is designed or intended primarily for children 12 or under and is subject to a CPSC safety rule, the rules are stricter. Before you import or distribute, you must send samples to a third-party laboratory that CPSC has accepted for the rules that apply, and your Children’s Product Certificate has to rest on that lab’s results.¹¹⁹ Internal testing does not work here. The certificate must name the accepted lab. If an exemption removes the need to test to a particular rule, you still issue a CPC and list the exemption instead of leaving the rule out.

Small batch manufacturers can qualify for relief from third-party testing on certain requirements, but only after registering with the CPSC.¹²

One boundary to note: medical devices are outside this system entirely. FDA regulates them through 510(k) notifications, Premarket Approval, and de novo classification, and a CPSC certificate does not apply to them.

What Happens If You Skip Certification

A vehicle imported without proper EPA and NHTSA declarations can be refused entry or seized by CBP. If you buy a vehicle that was brought into the country without a valid CBP entry, that vehicle is subject to seizure whether or not you knew about the problem when you bought it.⁷ A false declaration on the NHTSA HS-7 form carries a fine of up to $10,000, imprisonment for up to five years, or both.⁸ Importing a new vehicle without a current Certificate of Conformity is itself prohibited by the Clean Air Act.¹³

On the product side, distributing a product that requires a certificate without one violates federal law. CPSC can detain noncompliant imports at the port, order recalls, and pursue civil penalties against the manufacturer or importer.

1
US Environmental Protection Agency. How to Obtain a Copy of a Certificate of Conformity for a Light-Duty Vehicle
2
US Environmental Protection Agency. Locating the Vehicle Emissions Label
3
eCFR. 19 CFR 12.73 – Importation of Motor Vehicles and Motor Vehicle Engines
4
eCFR. 40 CFR Part 85 Subpart P – Importation of Motor Vehicles and Motor Vehicle Equipment
5
Office of the Law Revision Counsel. 49 USC 30112 – Prohibitions on Manufacturing, Selling, and Importing Noncomplying Motor Vehicles and Equipment
6
National Highway Traffic Safety Administration. List of Nonconforming Motor Vehicles Eligible for Importation
7
U.S. Customs and Border Protection. Requirements for Importing a Personal Vehicle or Vehicle Parts
8
National Highway Traffic Safety Administration. HS-7 Declaration – Importation of Motor Vehicles and Motor Vehicle Equipment
9
GovInfo. 15 USC 2063 – Product Certification and Labeling
10
U.S. Consumer Product Safety Commission. General Certificate of Conformity
11
U.S. Consumer Product Safety Commission. Children’s Product Certificate
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U.S. Consumer Product Safety Commission. Rules Requiring Third-Party Testing and a Children’s Product Certificate
13
Office of the Law Revision Counsel. 42 USC 7522 – Prohibited Acts