Unlike the EU, the US market does not have a unified “CE Mark”; instead, certification requirements for exports are a combination of regulations tailored to specific product categories: electrical safety falls under NRTL, consumer goods under CPSC, chemical substances under TSCA, and the California market adds California Proposition 65. Missing any of these requirements could result in goods being detained by customs.
This article outlines the certification checklist for exporting hardware structural components to the US by category.
I.
Electrical and Mechanical Safety: NRTL Certification
Products involving electrical or mechanical safety must undergo testing and certification by an OSHA-authorized NRTL (Nationally Recognized Testing Laboratory, such as UL, Intertek, or CSA) in accordance with ANSI/UL standards.
If hardware structural components are incorporated as parts into a UL-listed end product, they typically undergo UL “Recognition” (Component Recognition); complete units (with electrical functions) undergo UL “Listing.”
NRTL certification entails unannounced factory follow-up inspections (at least four times a year), and the certificate remains valid only through continued compliance.
II.
Consumer Goods: Attention Required for New CPSC Regulations
The US Consumer Product Safety Commission (CPSC) mandates Certificates of Compliance for regulated imported consumer goods. Starting July 8, 2026, compliance certificate data must be electronically filed (eFiling) via the ACE system before the goods arrive at the port; shipments lacking valid electronic data will be automatically intercepted and detained by the system.
Hardware consumer goods exported to the US (such as tools, locks, and home hardware) require a GCC (General Certificate of Conformity) prepared in advance and filed as required; products intended for children also require third-party testing and a CPC (Children’s Product Certificate).
This is a critical new regulatory change for US exports in 2026 that is easily overlooked.
III. Chemical & Environmental Regulations: TSCA and California Proposition 65
TSCA (Toxic Substances Control Act): Enforced by the EPA; importers of chemical substances or mixtures must submit an import certification (either a positive or negative declaration). While ordinary metal products free of TSCA-regulated chemicals may qualify for negative certification, items containing coatings, platings, or PFAS-related substances require special assessment. California Proposition 65: Applies to all products sold in California, regardless of origin. Products containing carcinogens or reproductive toxins—such as lead or cadmium—must be assessed against exposure limits and bear warning labels. Electroplated finishes, solder, and alloy compositions on hardware are common risk areas; companies have previously faced lawsuits following “60-day notices” due to lead content.
IV.
Construction Materials and Other Certifications
Architectural hardware (e.g., fire-rated door hardware, fire-resistant components) requires testing and UL certification under UL 10C/NFPA 252 or ASTM E119 standards. Bathroom hardware must meet NSF/ANSI standards and UPC/cUPC plumbing code certifications. Electronic hardware with RF capabilities requires FCC certification (Part 15). Exports may also be subject to anti-dumping duty reviews (categories such as fasteners have historically faced anti-dumping duties; verify current rates prior to export).
V.
Practical Advice: A Three-Step Approach to Building a Compliance Checklist
Step 1: Identify the governing agency based on product category (e.g., CPSC for consumer goods, NRTL for electrical/mechanical equipment, EPA for chemicals, or state-level agencies for California Proposition 65). Step 2: Conduct testing and obtain certifications based on applicable standards (prioritize confirming the specific certification bodies and standard versions required by your target customers). Step 3: Coordinate customs declaration procedures—starting in 2026, CPSC eFiling will be a mandatory pre-arrival requirement; ensure importers or customs brokers have access to the necessary certification data in advance.
Industry insiders advise that U.S. certification involves “checking boxes by category” rather than a “one-size-fits-all” pass;
to avoid wasted effort, you should first clarify the requirements of both the client and the regulators before investing in testing costs.
