CPSC eFiling is now mandatory for imported finished products that already require a CPC or GCC. CPSC put the program into effect on July 8, 2026. Certificate data must reach CBP through ACE when the filer submits the entry. If the filer submits the entry and entry summary together, the data must accompany that filing.
Importers should map each product to CPSC rules and collect factory and laboratory records. Importers should choose a Full or Reference PGA Message Set before shipment. Mismatched data can raise an entry’s risk score, trigger review, or expose a certificate gap. This guide covers filing scope, data fields, workflow, and error controls.
Who Must Comply with CPSC eFiling and When?
Importers must eFile when an imported finished product requires a CPSC certificate. The certificate may be a Children’s Product Certificate (CPC) or General Certificate of Conformity (GCC). CPSC made eFiling mandatory for general imports on July 8, 2026. Products entered from an FTZ for consumption or warehousing become subject on January 8, 2027.
Imported Products That Require a CPC or GCC
A children’s product requires a CPC when a children’s product safety rule covers the finished product. The importer issues the CPC for goods made overseas. The importer must base the CPC on passing results from a CPSC-accepted third-party laboratory, unless a valid testing exclusion applies.
A general-use product requires a GCC when a CPSC rule, ban, standard, or regulation requires certification. The importer bases the GCC on a test of each product or a reasonable testing program.
|
Imported product |
Certificate basis |
eFiling result |
|---|---|---|
|
Children’s product covered by a certification rule |
CPC, usually based on CPSC-accepted third-party testing |
eFiling required |
|
General-use product covered by a certification rule |
GCC, based on testing or a reasonable testing program |
eFiling required |
|
Finished product with no applicable certification rule |
No CPC or GCC for that product |
eFiling not required |
The importer remains responsible for certificate accuracy, even when another party prepares part of the record. Importers should identify the Importer of Record and responsible certifier before entry because the two roles can differ. CPSC importer guidance explains when an owner, purchaser, consignee, or authorized broker may fill those roles.
When a CPSC Certificate and eFiling Are Not Required
eFiling does not apply when the imported product does not require a certificate. Common cases include:
- The product falls outside CPSC jurisdiction.
- No CPSC rule, ban, standard, or regulation requires certification for the finished product.
- The importer will use the item only as a component and will not distribute it as a finished consumer product.
- CPSC has issued enforcement discretion that covers the product.
- A consumer sends a genuine noncommercial gift or personal effect to another consumer.
- The used product predates the applicable CPSC rule and never required certification.
Sample-only products may also fall outside the requirement, but the facts must support that treatment. CPSC says a sample cannot enter US commerce or reach consumers. Importers should document the final disposition and mark or alter the sample when appropriate. A “sample” label alone does not control the result. CPSC sample-only guidance explains the required limits.
A testing exclusion creates a different result. The product may still require a CPC or GCC when a specific testing exclusion applies. The importer then files the certificate with the correct testing exclusion code.
Compliance Dates for General Imports and FTZ Entries
The 90 FR 1800 final rule and CPSC certificate update set the following compliance dates:
|
Import scenario |
Compliance date |
Filing point |
|---|---|---|
|
General import entered for consumption or warehousing |
July 8, 2026 |
When the filer submits the entry, including a combined entry and entry summary filing |
|
Merchandise entered from a Foreign Trade Zone for consumption or warehousing |
January 8, 2027 |
FTZ entry, including applicable type 06 or weekly entry processes |
The later FTZ date does not remove the certificate requirement. FTZ operators and importers should connect inventory records to the finished product certificate before the January deadline.
What Data Must Importers Submit for CPSC eFiling?
Each eFiled certificate must identify one finished product and connect that product to its rules, production record, tests, laboratories, and record contact. The importer should build the data record at product level. Shipment-level descriptions such as “toys” or “household goods” cannot reliably match the certificate to one finished product.
Seven Required Certificate Data Elements
CPSC’s eFiling FAQ describes seven required certificate data elements:
|
Required element |
What the importer should provide |
|---|---|
|
Product ID |
GTIN, SKU, UPC, model number, serial number, registered number, or another unique alphanumeric ID |
|
Citation codes |
Every applicable CPSC rule, ban, standard, or regulation covered by the certificate |
|
Manufacture date |
At least the month and year, with accurate batch timing when production is continuous |
|
Manufacture place |
Final assembly location, including city or region and country, plus a street address when needed to distinguish factories |
|
Product test date |
The date when the product was most recently tested for each applicable requirement |
|
Testing laboratory |
Each laboratory relied on, with the required identity and contact details |
|
Point of contact |
The person who maintains supporting test records, with the required contact details |
The certificate must also identify the certifying party. A Reference PGA Message Set uses the Certifier ID to retrieve the stored record.
Citation Codes and Testing Exclusion Codes
Citation codes name the legal requirements covered by the certificate. One product may need multiple codes. A children’s toy may have separate requirements for lead, small parts, phthalates, and applicable toy safety sections.
Testing exclusion codes explain why a listed requirement did not use the standard testing path. The code must match an actual exemption, exception, determination, or approved small-batch testing relief. A testing exclusion code does not remove the underlying rule or the certificate duty. Importers should use the current CPSC citation and exclusion files for the product, not codes copied from a similar SKU. CPSC warns that its published HTS, citation, and exclusion lists are guidance and are not exhaustive.
Test Dates, Laboratories, and Supporting Records
The certificate must show the most recent testing relied upon and identify every laboratory tied to that support. When component testing supports the finished product certificate, the certificate record must connect each laboratory to the relevant citation.
Test report URLs, report IDs, and report keys are optional eFiling fields. The underlying reports are not optional records. CPSC may request reports or other support after entry, so the record contact must be able to retrieve complete supporting documents promptly.
Use the same Product ID on the certificate, packing list, and commercial invoice. A model number that changes across documents can prevent CPSC or CBP from matching the entry line to the certificate.
How Does CPSC eFiling Work Through CBP ACE?
The importer certifies the product data, and the customs filer transmits a CPSC PGA Message Set through CBP ACE. Importers can file all certificate data with the entry or reference a certificate stored earlier in the CPSC Product Registry. A Disclaim message is optional when no certificate applies.
Who Prepares, Certifies, and Files Certificate Data
The workflow separates product knowledge from customs transmission:
|
Party |
Main responsibility |
|---|---|
|
Foreign manufacturer and laboratory |
Supply production details, test results, laboratory data, and change notices |
|
Importer or responsible certifier |
Determine applicable rules, issue an accurate CPC or GCC, and approve the certificate data |
|
Customs broker or other authorized filer |
Send the Full, Reference, or optional Disclaim PGA Message Set through ACE |
|
CPSC and CBP |
Use the entry and certificate data for review, targeting, and admissibility decisions |
For eFiling, CPSC starts with the Importer of Record eligible to make entry. If an authorized broker lacks enough product knowledge, the broker may name the owner, purchaser, or consignee as the responsible certifier.
The laboratory does not issue the CPC. The broker’s transmission does not transfer the certifier’s responsibility for a false, incomplete, or unsupported certificate.
Full PGA Message Set for Limited or One-Time Imports
A Full PGA Message Set sends all seven certificate data elements with the entry, so the CPSC Product Registry is not required. The Full method fits limited imports, one-time products, or certificates that change too often to justify registry maintenance. The broker needs the complete dataset for every affected entry line. Late supplier details can stop the filing team from completing the message before release.
Use a line-level data sheet that separates each finished product. The final rule requires each certificate to describe one finished product. Create separate records when model, material, factory, or other differences change product identity or the compliance basis.
Reference PGA Message Set and Product Registry Identifiers
A Reference PGA Message Set fits products imported repeatedly under the same certified data. The importer stores and certifies the full product record in the CPSC Product Registry before entry. The broker then sends three identifiers:
- Certifier ID
- Product ID
- Version ID
The Product Registry does not send data to ACE by itself. The importer must give the three identifiers to the broker for each applicable entry line. Importers can add records manually or use CSV and API upload options.
Create a new version when certificate facts change. A new factory, material change, updated testing basis, or corrected citation may make the old version inaccurate. The Product ID should remain stable only when the identifier still describes the same finished product.
When a Disclaim PGA Message Set May Apply
A Disclaim PGA Message Set is optional when CPSC flags the HTS code and the finished product needs no certificate data. A valid disclaim may cover a product outside CPSC jurisdiction, a product without a certification rule, or an imported component.
A disclaim does not cure a missing CPC or GCC. The importer should keep the product analysis that supports the disclaim and give the broker the correct reason. HTS flags may trigger CPSC review, but the HTS code alone cannot establish that a certificate is unnecessary.
How Can Importers Reduce CPSC eFiling Errors and Holds?
Importers can reduce preventable eFiling errors by finishing the product analysis and certificate record before cargo departs. CPSC says complete certificate data can affect entry risk scoring. Product IDs, rules, factory details, tests, and broker instructions should match before the customs entry reaches ACE.
Confirm Applicable Rules and Certificate Type Before Production
Complete these checks before approving mass production:
- Classify the product by intended user, design, materials, labeling, and use.
- Identify every applicable CPSC rule instead of relying only on the HTS flagging list.
- Decide whether the finished product requires a CPC, GCC, or no certificate.
- Confirm CPSC-accepted laboratory testing for children’s products unless a valid exclusion applies.
- Document the test or reasonable testing program that supports a GCC.
A wrong certificate type can hide missing tests until the cargo reaches the port.
Collect Required Supplier and Laboratory Details Before Cargo Leaves China
For shipping from China to the USA, collect the following information before departure:
- Exact finished product ID used on the invoice and packing list
- Final assembly factory name, address, city, and country
- Manufacture month and year for the shipment or batch
- Applicable CPSC citation codes and testing exclusion codes
- Most recent supporting test dates and laboratory details
- Record keeper’s name, address, email, and telephone number
- Full test reports and any component certificates used as support
Supplier delays become entry delays when the broker cannot complete a Full PGA Message Set. Reference filings carry the same risk when the stored certificate is incomplete or outdated.
A global freight forwarder can coordinate cargo documents and departure timing. The certifier controls certificate accuracy, while the customs filer controls ACE transmission.
Keep Product IDs and Certificate Versions Consistent Across Documents
Choose one primary identifier that appears on the product packaging, invoice, packing list, and certificate. CPSC recommends a visible identifier because inspectors must match the physical product to the electronic record.
Track the Product ID, Version ID, factory, test basis, effective date, and replacement status in one certificate log. When certificate data change, certify a new Version ID and use it for future entries. The Product Registry User Guide states that archiving a product certificate also archives all previous versions. The Product Registry cannot archive one old version by itself.
Do not reuse a certificate after a material change without reviewing the testing and certification effect. A color change may be administrative for one product but may change coatings, materials, or chemical test results for another.
Send Complete Certificate Data to the Broker Before Entry
Give the broker either the full seven-element dataset or the correct Certifier ID, Product ID, and Version ID. The broker also needs the entry-line mapping when one shipment contains multiple regulated products.
Ask the broker to confirm the filing method, identifiers, and ACE response messages before release. Missing or inaccurate certificate data may trigger review or enforcement. The wider customs clearance process includes other entry documents, duties, and agency filings.
FAQs
Does CPSC eFiling Create New Product Testing or Certification Requirements?
No. CPSC eFiling changes how importers transmit existing certificate data. The July 8, 2026 implementation did not create new testing or certification duties. A product needs eFiling only when an existing CPSC rule already requires a CPC or GCC, although the revised rule updates certificate content requirements.
Does Small Batch Manufacturer Status Exempt an Importer from CPSC eFiling?
No. Small Batch Manufacturer status may change the testing method for certain children’s product rules, but it does not remove the CPC requirement. If an imported product requires a CPC, the importer must eFile the certificate data.
Do Product Samples That Are Not for Sale Require CPSC eFiling?
Genuine sample-only products may avoid certification and eFiling when the products never enter US commerce or reach consumers. Importers should keep records that show final disposition and use markings that make distribution unlikely. The sample treatment ends once the importer sells the product, gives it to a consumer, uses it in a consumer trial, or resells it.
If a Product’s HTS Code Is Not on the CPSC Flagging List, Is eFiling Still Required?
Yes. An unflagged HTS code does not exempt a product covered by a CPSC certification rule. The CPSC HTS flagging list is not exhaustive, so importers must assess intended use, age grading, materials, and applicable safety rules.
Are Section 321 Shipments Exempt from CPSC eFiling?
No. Section 321 does not exempt a product that requires CPSC certification. Shipment value does not remove the filing duty. A Disclaim PGA Message Set applies only when the product does not require certificate data. For non-gift shipments sent by international mail, the sender must file the certificate in the Product Registry before US arrival.
No. CPSC eFiling changes how importers transmit existing certificate data. The July 8, 2026 implementation did not create new testing or certification duties. A product needs eFiling only when an existing CPSC rule already requires a CPC or GCC, although the revised rule updates certificate content requirements.
No. Small Batch Manufacturer status may change the testing method for certain children’s product rules, but it does not remove the CPC requirement. If an imported product requires a CPC, the importer must eFile the certificate data.
Genuine sample-only products may avoid certification and eFiling when the products never enter US commerce or reach consumers. Importers should keep records that show final disposition and use markings that make distribution unlikely. The sample treatment ends once the importer sells the product, gives it to a consumer, uses it in a consumer trial, or resells it.
Yes. An unflagged HTS code does not exempt a product covered by a CPSC certification rule. The CPSC HTS flagging list is not exhaustive, so importers must assess intended use, age grading, materials, and applicable safety rules.
No. Section 321 does not exempt a product that requires CPSC certification. Shipment value does not remove the filing duty. A Disclaim PGA Message Set applies only when the product does not require certificate data. For non-gift shipments sent by international mail, the sender must file the certificate in the Product Registry before US arrival.
