The Child Nicotine Poison Prevention Act of 2015 gives the Consumer Products Safety Commission (CPSC) authority over the packaging of liquid nicotine containers, which you can read here.
What it means for your business:
If you are a manufacturer, you need to request a GCC (General Certificate or Conformity) from your bottle manufacturer and copy of the testing protocols. You can review this sample testing protocol from Rock Bottom Bottles, LLC. This certificate ensures that the manufacturer has gone through testing that would enable them to be compliant under 16 CFR 1700.15 testing standards and obtain the test results for such. The testing standards certificate should be available to you for verification. You will need to provide a GCC to all resellers of your e-liquid with your logo and company information (see example below).
If you are a retailer (only buy and sell e-liquid to your customers), you should obtain a GCC from your manufacturer, that references their brand, logo and company information on the certificate. This ensures they have the testing documentation proving their bottles are in compliance. Any inspector will verify testing documentation compliance with the manufacturer directly.
Please note the following:
- An ISO-8317 certificate is not in compliance with this regulation and will not be admissible. Most Chinese manufacturers will try to give you this for compliance but this will not be admissible. Only Bottles meeting the US 16 CFR Title 16 Part 1700.20 standard will be approved
- This only applies to products that were manufactured AFTER July 26th. If you have products that were manufactured prior to that date these requirements are not needed BUT you do need to be able to prove when it was manufactured. Without evidence it will be assumed they were manufactured after July 26th. ***CPSC has clarified their position and starting July 26, 2016, all products must be child-resistant regardless of manufacturing date. Read more on this change here.***
- Please retain receipts from your bottle manufacturer that verifies your bottles match those the documentation references.
- There will be a separate GCC required for glass and plastic bottles including those of different sizes.
Sample General Certificate of Conformity
(insert your logo at top of page)
1.Identification of the product covered by this certificate (List what lines of liquid are covered by this GCC. You do not need to list specific flavors:):
Awesome Sauce Liquids
2. Citation to each CPSC product safety regulation to which this product is being certified:
16 CFR Title 16 Part 1700.20
3. Identification of the U.S. importer or domestic manufacturer certifying compliance of the product:
Big Bubbas Liquids
123 Main street
4. Contact information for the individual maintaining records of test results:
Big Bubbas Liquids
Bubba Johnson 941-555-5555
5. Place where this product was manufactured:
Luqua Sijiazhuang Hebei Povince, China
6. Date and place where this product was tested for compliance with the regulation(s) cited:
Testing conducted from 09-12-2015 -10-3-2015
Chicago and south, west villages thereof
7. Identification of any third-party facility on whose testing the certificate depends:
Bitner Associates, Inc.
1001 Forest Trail Sugar Grove, IL 60554