CPSC eFiling Mandate — Effective July 8, 2026

Effective July 8, 2026, the U.S. Consumer Product Safety Commission (CPSC) requires all importers of regulated consumer products to electronically file (eFile) their Certificate of Compliance (CoC) data with U.S. Customs and Border Protection (CBP) at the time of entry. This is a change in how certification data is submitted — not which products require certification. The requirement was approved as a Final Rule on December 18, 2024 and published in the Federal Register on January 8, 2025.

Regulatory Background

The CPSC has long required importers of consumer products subject to a safety rule, ban, standard, or regulation to certify compliance. Previously, these certificates had to accompany the physical shipment or be available on request. The eFiling mandate aligns CPSC with other U.S. government agencies — such as the FDA, USDA, and EPA — that already require electronic data submission at entry.

The rule amends 16 C.F.R. Part 1110 and standardizes both what data must be included in certificates and how it must be submitted.

Implementation Timeline

Milestone	Date
Final Rule approved	December 18, 2024
Published in Federal Register	January 8, 2025
Technical correction issued	September 24, 2025
Mandatory eFiling for standard imports	July 8, 2026
Mandatory eFiling for Foreign Trade Zone (FTZ) entries	January 8, 2027

FTZ importers receive a delayed compliance date of January 8, 2027 to allow additional time for process adaptation.

Who Is Affected

The eFiling requirement applies to:gocubic

Importers of record (IOR): Any business importing CPSC-regulated consumer products into the U.S. for consumption, warehousing, or distribution
Private labelers: Businesses whose brand appears on regulated products
Cross-border eCommerce sellers: International sellers shipping direct-to-consumer into the U.S. from any country — China, UK, India, Canada, Australia, or elsewhere
B2C shippers: There is no low-value exemption — even a $25 shipment of children's toys requires eFiling if the product is regulated
Low-value shipment senders: Products claiming the Section 321 de minimis exemption (under $800) are explicitly not exempt from eFilingg

The CPSC FAQ explicitly states: "There is no Section 321 (also known as de minimis) shipment exemption for eFiling.

Impacted Product Categories

CPSC has identified approximately 600 HTS codes in ACE for mandatory review, selected based on historical import and risk data indicating at least half of products in each code typically require certification. Products imported under non-flagged codes may still require eFiling if they fall under a CPSC rule or standard.

Children's Products — Children's Product Certificate (CPC) Required

Children's products are defined as those primarily designed for use by children 12 years and under. CPC requires third-party lab testing by a CPSC-accredited lab.

Subcategory	Products
Sleep & nursery furniture	Full-size cribs, non-full-size cribs, bassinets & cradles, bedside sleepers, play yards, toddler beds, crib mattresses, mattresses & mattress pads
Seating & carrying	High chairs, booster seats, infant bouncer seats, portable hook-on chairs, frame child carriers, soft/sling infant carriers, stationary activity centers
Mobility	Carriages & strollers, infant walkers, infant swings
Safety & sleep products	Infant bath seats, infant bath tubs, infant sleep products, infant support cushions, nursing pillows, portable bedrails, gates & enclosures, baby changing products
Apparel & textiles	Children's sleepwear (sizes 0–6X), children's sleepwear (sizes 7–14), wearing apparel, vinyl plastic film
Toys & play	Children's toys, electrically operated toys, clacker balls, dive sticks, rattles, toy/look-alike firearms, small parts
Furniture	Bunk beds (children's), children's folding chairs & stools, clothing storage units
Hazardous materials	Total lead content, lead in paints & surface coatings, phthalates, magnets, button cell or coin batteries
Recreation	Bicycles, bicycle helmets, all-terrain vehicles (ATVs)
Other	Pacifiers, hand-held infant carriers

General Consumer Products — General Certificate of Conformity (GCC) Required

GCC covers non-children's consumer products subject to CPSC rules. General-use testing does not require a third-party lab (a "reasonable testing program" suffices).

Subcategory	Products
Home furnishings & textiles	Carpets & rugs (large & small), mattresses & mattress sets/pads, bunk beds, clothing storage units
Home improvement	Drywall, cellulose insulation, architectural glazing materials, consumer patching compounds
Outdoor & recreation	ATVs, bicycles, bicycle helmets, walk-behind power lawn mowers, swimming pool slides (freestanding), pools & spas
Fire & safety	Cigarette lighters, multipurpose lighters, matchbooks, fireworks, metal-cored candlewicks, artificial emberizing materials
Appliances & electronics	Garage door openers, CB antennas
Safety devices	Adult portable bed rail, liquid nicotine packaging, portable fuel containers (flame mitigation & special packaging), refrigerator doors, refuse bins
Other	Wearing apparel, vinyl plastic film, magnets, button cell batteries, toy/look-alike firearms, dive sticks, lead in paints, lawn darts, special packaging

Note: Some products appear in both lists because they are regulated regardless of whether they are children's or general-use products (e.g., magnets, button cell batteries, carpets & rugs).compliancegate

Products NOT Required to eFile

eFiling is generally not required for:

Raw materials or component parts (only finished consumer products are regulated)
Products not subject to any CPSC rule, ban, standard, or regulation
Adult wearing apparel qualifying under specific flammability exemptions
Gifted products shipped between two private individuals (non-commercial)
Domestic manufacturers (for now — similar requirements may follow in future regulatory phases)

B2C and Direct-to-Consumer Shipping: Full Impact

This is one of the most operationally significant aspects of the mandate for logistics businesses:

Issue	Detail
No de minimis exemption	All shipments — regardless of value — must comply if the product is CPSC
No low-value shipment exemption	A $25 toy requires the same eFiling as a $25,000 pallet
Separate customs entry required	Shipments under $2,500 no longer eligible for informal consolidated clearance — a separate entry is needed, potentially incurring additional fees
IOR responsibility	The Importer of Record (IOR) is fully and legally responsible for the accuracy of all CoC data, even if a shipper or 3PL uploads data on their behalf
DAP/DDP implications	In DAP arrangements, the US buyer is the IOR and legally responsible — but depends on the seller for certificate data. In DDP, the seller assumes full IOR responsibility
Power of Attorney	For CPSC-regulated shipments with total value over $5,000 USD, a Power of Attorney must be on file with the customs broker
Country of origin irrelevant	The trigger is the product's HTS code and CPSC status — not where it ships from

The Seven Required Data Elements

Regardless of filing method, the following seven data elements must be provided for each regulated product per shipment:

Product Identifier — One of: GTIN, SKU, UPC, Model Number, Serial Number, Registered Number, or Alternate ID
Cited Safety Rule — The specific CPSC regulation(s) to which the product is certified (e.g., 16 CFR Part 1250)
Date of Manufacture — Manufacture/production/assembly date of the finished product
Place of Manufacture — Name, full address, and contact information of the manufacturing party
Date of Most Recent Compliance Testing — Date of the most recent product compliance test
Testing Laboratory Contact Information — Name, full address, and contact information of the testing lab
Records Keeper Contact Information — Name, full address, and contact information of the party maintaining test result records

Two Filing Methods

Importers may choose one of two methods to transmit data through ACE:foley+1

Method 1: Full PGA Message Set

Submit all seven data elements with each customs entry via a CPSC Participating Government Agency (PGA) message set in ACE.

Best for: Importers with a small number of regulated products, infrequent shipments, or highly variable product mixes
Drawback: Data must be re-entered for every individual shipment, making it more time-intensive at scalefoley

Method 2: Reference PGA Message Set (Recommended for Repeat Shippers)

Pre-register product certificate data in CPSC's secure Product Registry (a separate CPSC repository from ACE). At time of entry, only three identifiers are transmitted in ACE:

Product ID
Certifier ID
Version ID

Best for: Importers repeatedly shipping the same SKUs — data is entered once, then referenced indefinitely
Advantage: Reduces invoice data burden, speeds clearance, and lowers risk of data entry errors
Note: Data in the Product Registry must be updated whenever product information changes (e.g., new manufacturing batch)

Submitting CPSC CoC via Spaceship Pro

Spaceship Pro's Customs Declaration section includes an "Add Supporting Documents" feature that allows customers to upload a PDF (max 5MB) alongside their shipment.

How to Upload a Supporting Document on Spaceship Pro

Go to Customs Declaration when creating or editing a shipment
Check "Add supporting documents"
Select "Other Documents (e.g. MSDS)" from the dropdown
Click Upload and attach the CoC PDF (max 5MB, PDF format only)

Shipment Review Statuses in ACE

When a shipment is flagged or selected for CPSC review, CBP's 1USG Messaging Program communicates the status to importers:

Status	Meaning
Under Review	Shipment may move to importer's premises but cannot enter commerce until CPSC completes review
Hold Intact	Shipment is held for examination and cannot move until released by CPSC
May Proceed	Shipment cleared CPSC review (may still require other agency clearance)
1USG Clearance	CBP-issued confirmation that all relevant agencies have cleared the shipment

Consequences of Non-Compliance

Failure to properly eFile can result in:

Shipment holds or delays — CBP places the shipment under review until certificate data is submitted
Physical examination — Products without proper eFiling face higher inspection rates
Accumulating storage fees — Cargo held at ports incurs demurrage and warehouse costs
Additional information requests — CPSC may require documentation before release
Refusal of entry — The shipment may be denied release entirely
Customs broker liability — Brokers filing entries without required CPSC data may be held personally liable by the CPSC
Applicable PGA submission fees

Importers must also maintain compliance certificates and supporting test or certification records for at least five years from the certificate creation date.

Step-by-Step Compliance Checklist

Step 1: Review your product catalog against the CPSC's ~600 flagged HTS codes (available at cpsc.gov/eFiling)
Step 2: Determine certificate type — GCC (general consumer product) or CPC (children's product requiring third-party testing)
Step 3: Choose a filing method — Full PGA Message Set or Reference PGA Message Set
Step 4: If using Reference method, register on CPSC Product Registry at cpsc.gov/eFiling-CPSC-Product-Registry
Step 5: Update commercial invoice templates to include a Remarks field or addendum for CPSC data
Step 6: Brief manufacturers and suppliers — manufacturing date, location, and lab details must come from them
Step 7: Confirm Power of Attorney status with customs broker (required for shipments over $5,000 USD)
Step 8: Designate a central point of contact for eFiling coordination across supply chain partners
Step 9: Update internal compliance programs and train relevant staff
Step 10: Monitor CPSC for updates to flagged HTS codes and regulatory changes

CPSC Official Resources

Resource	Purpose	Link
CPSC eFiling Hub	Central documentation and updates	cpsc.gov/eFiling
Product Registry	Register products and store certificate data	cpsc.gov/eFiling-CPSC-Product-Registry
eFiling Quick Start Guide	Step-by-step instructions for getting started	Available at cpsc.gov/eFiling
Regulatory Robot	Determine which CPSC standards apply to specific products	cpsc.gov (search "Regulatory Robot")
eFiling Document Library	Flagged HTS code list and reference materials	cpsc.gov/eFiling
eFiling FAQ	Official answers to common questions	cpsc.gov/FAQ/eFiling-Frequently-Asked-Questions-FAQ
Email Support	Technical assistance	eFilingSupport@cpsc.gov

Frequently Asked Questions (FAQ)

Q: Does eFiling apply to all US-bound shipments?
A: It applies to any shipment of finished consumer products that fall under an CPSC rule, ban, or standard — regardless of origin country, shipment size, or value.

Q: Is there a de minimis exemption for low-value packages?
A: No. The CPSC FAQ explicitly confirms there is no Section 321 (de minimis) exemption. Even products under $800 in value must comply if they are CPSC-regulated.

Q: Can my freight forwarder or customs broker file on my behalf?
A: Yes, your customs broker or courier handles transmission to CBP — but they can only transmit data you supply. They cannot generate or certify compliance. The Importer of Record remains legally responsible for accuracy.

Q: What if my product's HTS code is not on the flagged list?
A: eFiling is not required for that specific entry, but your product may still fall under CPSC regulations. Keep valid GCC/CPC documentation on file in case of a request. Use the CPSC Regulatory Robot to confirm.

Q: Do I need to re-file if manufacturing details change between batches?
A: Yes. Certificate data must be accurate and current. If using the Product Registry, update registered product data whenever manufacturing information changes.

Q: What about shipments into Foreign Trade Zones?
A: FTZ-imported goods have a delayed compliance date of January 8, 2027.

Q: Is eFiling required for electronics?
A: Not automatically for all electronics. However, electronic toys or electronics containing button cell batteries or magnets are likely covered due to those specific component rules.

Q: What if I ship on DDP terms?
A: Under DDP, the seller handles customs clearance on the buyer's behalf and assumes Importer of Record responsibility. Full eFiling compliance is the seller's obligation

Last Updated On 7 Jul 2026