Tier C · channel & record operating file · one per model, per year · status as at 10 November 2026

The recurring duties that keep a compliant pack saleable

Certification is a project; staying on the shelf is a rota. This is the file that holds the repeating duties, the listing audit, the record vault and the change log for one model. It reads the gap check's export, so the two agree on which of the 26 evidence items are open.

Brand SKU / model Cell / pack supplier Register year Owner at the importer As at

Duties open

of 10 recurring

Record vault

of 12 documents held

2028 re-test

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days to 1 Jan 2028

Change flags

build changes since cert

1 · Recurring duties item numbers refer to the 26 on us-gap-check.html · ✓ done · S due · ✗ blocked

Each line is a duty that recurs, not a document you obtain once. The cadence column is what makes it a Tier C item: the certificate itself is Tier A, but the mark on the carton has to be right on every print run for as long as you ship.

#	Duty	Items	Cadence	Owner	Evidence ref	Last done	State

2 · The next twelve months dated obligations only — nothing is projected that the file does not know

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3 · Listing audit, per channel NYC § 20-610 reaches the online product page specifically

The cheapest failure in this whole map: a compliant pack, a correct certificate, and a product page that does not show the certification or the laboratory's identity. Item 5 is the listing duty; item 6 the fire-safety disclosure. Audit each channel after any copy change, not once a year.

Channel	Lab name or mark shown	Certification standard shown	Fire-safety disclosure	SKU matches cert scope	Audited	By

4 · Record vault what a buyer, a retailer's QA or an attorney general asks for — and can you produce it today

California § 26304 requires a copy of the laboratory's test report on request. The duty is not to have filed it; it is to be able to hand it over. Record where each original lives, not just that it exists.

#	Document	Items	Holder	Location	Issued	Expires	Retrieval	Held

5 · Change log — the trigger list a certificate describes one tested combination

Tick anything that has changed since the certificate was issued. None of these is a paperwork update: each one means the certificate no longer describes what is in the carton, and the answer is a scope review or a re-test, not a new label.

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6 · What this file does not do

It does not certify anything. It records who holds which document and when it was last checked. A tick in this file is a claim by the owner named beside it, not a finding.
Federal law is missing from it on purpose. CPSC 16 CFR 1265 is proposed (91 FR 38162, 24 June 2026), not law, so it creates no recurring duty yet. When a final rule publishes, the docket watch prints the edit list and this file gains a group.
DC is carried as pending. B.26-0244 was signed 16 October 2026 and takes effect after congressional review; the penalty schedule was not verified, so no figure appears anywhere in this file.
The 2028 cliff is the only dated cliff here. Illinois drops EN 15194 for low-speed e-bike drive systems on 1 January 2028. The countdown is calendar days, not business days, and says nothing about lab queue times — book re-testing months before it, not on it.
Retrieval times are self-declared. If the vault says four hours and the original sits with a supplier in another time zone, the declaration is wrong. Test one request per quarter rather than trusting the column.

Owner at the importer · date the register was last walked

Next walk · suggested quarterly, and after any build change