CPSC eFiling is the requirement, in effect since July 8, 2026, that importers of CPSC-regulated consumer products electronically file certificate of compliance data with U.S. Customs and Border Protection (CBP) at entry. It covers any finished product that needs a certificate, which means General Certificates of Conformity (GCCs) for non-children’s products as well as Children’s Product Certificates (CPCs). The importer supplies seven data elements, or three certificate identifiers from CPSC’s Product Registry, and the customs broker transmits them. Shipment value does not matter: CPSC’s FAQ says there is no de minimis exemption.
This guide covers the import side across all regulated products. For the children’s certificate itself (who issues it, its elements, lab testing), see our Children’s Product Certificate guide, which this article builds on rather than repeats.
Sources: CPSC eFiling FAQ, CPSC news release 26-604 (July 8, 2026), and the Federal Register final rule 90 FR 1800 (January 8, 2025). Data checked 2026-10-06.
What CPSC eFiling Is, and What It Is Not
The final rule, published January 8, 2025, revises CPSC’s certificates regulation (16 CFR part 1110) and “implements, for importation of products and substances regulated by CPSC, electronic filing of certificates (eFiling) with CBP,” per its Federal Register abstract.
Two dates matter:
| Shipment type | eFiling effective date |
|---|---|
| Most imported regulated consumer products | July 8, 2026 |
| Products entered from a Foreign Trade Zone (FTZ) for consumption or warehousing | January 8, 2027 |
What eFiling does not do is create new compliance duties. CPSC’s July 8, 2026 release quotes Acting Chairman Peter A. Feldman: “It creates no new testing, certification, or compliance obligations. Importers are already required by law to create and maintain this information. eFiling simply modernizes how the data is transmitted to CPSC.”
In practice the change is timing and format. Before, you had to have the certificate and produce it on request. Now its data travels with the customs entry, before the goods enter U.S. commerce. If your certificate was incomplete or missing, eFiling turns a latent problem into one visible at the border.
The same release states that “eFiling does not apply to domestic manufacturers, including small businesses manufacturing in the United States.” It applies to imports.
Which Imported Products Need an eFiled Certificate
The trigger is certification: if a finished consumer product must be certified to a CPSC rule, ban, standard, or regulation, its import needs an eFiled certificate. The final rule uses the term “finished product certificate,” which it says encompasses GCCs and CPCs.
- Non-children’s regulated products (GCC). The final rule: “Certificates for non-children’s products (General Certificates of Conformity or GCCs) must be based on a test of each product or a reasonable testing program.” The certificate and its eFiled data are required either way.
- Children’s products (CPC). Same eFiling mechanics; the certificate must rest on CPSC-accepted third-party lab testing. Details are in the CPC guide.
- Resold and overstock goods. CPSC’s FAQ answers “Yes”: regulated finished products “to be distributed in commerce” must meet eFiling, “This includes both resold products and overstock products.”
- Used products. If made after the relevant rule took effect and imported in a commercial transaction, eFiling applies. If made before, no certificate is required, so eFiling does not apply.
- Consumer-to-consumer sales. The FAQ exempts gifts and personal effects, not sales: “Transactions involving the sale of a product, including sales by one consumer to another consumer through an online marketplace or other sales platform, are commercial transactions and are not covered by this exemption.”
- Replacement parts. Per the final rule, “Imported replacement parts for bicycles, power mowers, or any non-children’s product covered by a finished product regulation are not subject to the eFiling requirement unless a regulation applies to the part, as sold.”
- Samples. Products imported only as samples, not for U.S. consumers, do not need to meet CPSC product safety requirements, but CPSC may review them at entry and you must be able to show they will not reach consumers.
CPSC’s FAQ does not mention Amazon or FBA by name. The obligation attaches to the importer on the customs entry, so the useful question is who is importer of record for each shipment. If that is you, the filing is yours to arrange. If you are unsure whether a product is regulated, CPSC’s FAQ points to its Regulatory Robot and its Small Business Ombudsman ([email protected]).
The Seven Data Elements CPSC Requires
When the importer files a Full PGA Message Set, CPSC’s FAQ lists the required data: “the Product ID, Citation Codes, Manufacture Date, Manufacture Place, Product Test Date, Testing Laboratory, and Point of Contact.”
| Data element | What to have ready |
|---|---|
| Product ID | One of seven ID types: GTIN, SKU, UPC, Model Number, Serial Number, Registered Number, or Alternate ID |
| Citation Codes | Codes for every CPSC rule, ban, standard, or regulation the product is certified to |
| Manufacture Date | When the product (or batch) was made |
| Manufacture Place | Where it was made |
| Product Test Date | The most recent date of testing |
| Testing Laboratory | Each lab that tested, tied to the rules it tested for |
| Point of Contact | The contact listed on the certificate |
Three details from the FAQ trip up importers:
- Pick a Product ID that is on the paperwork. CPSC “strongly recommends that users provide at least one product identifier that can be found on the product packaging, product packing list, and/or on the product invoice.”
- Component testing counts. If you rely on component part tests, each lab must appear on the certificate, linked to the rules it tested for. As of July 8, 2026, revised part 1110 “also requires identification of any testing exclusions relied upon.”
- Some fields are optional. Test URL, Test Report Key, and Test Report ID are “optional, but encouraged,” and CPSC may still ask for supporting test records.
These elements largely mirror what a compliant GCC or CPC already contains. If your supplier’s certificate cannot produce all seven, fix the certificate before the shipment books.
Full vs. Reference PGA Message Set
CPSC offers two ways to get the data into CBP’s Automated Commercial Environment (ACE):
| Full PGA Message Set | Reference PGA Message Set | |
|---|---|---|
| What the broker files | All seven data elements, every entry | Three Certificate Identifiers: Certifier ID, Product ID, Version ID |
| Product Registry needed? | No | Yes, data pre-entered by the importer |
| Best for | Occasional imports, few SKUs | Repeat imports of the same certified products |
| Bulk options | Not applicable | CSV upload or API |
| Who keeps it current | Importer re-sends to broker each time | Importer updates the Registry entry and its Version ID |
CPSC’s FAQ says Reference sets “are preferable if the importer repeatedly imports regulated consumer products covered by the same product certificates.” As long as certificate details are identical, one Registry entry can be referenced across shipments.
Two caveats. The Registry “does not communicate with CBP’s ACE system,” so you still send the three identifiers to your broker. And “A CPSC Reference PGA Message Set requires an entry and therefore cannot be attached to a CBP manifest.”
For a seller with a stable catalog of regulated SKUs, we recommend the Registry route: enter each certificate once, then send the broker three identifiers per product instead of seven fields.
Why Your Customs Broker Files It
Under both options, CPSC’s FAQ describes the broker transmitting the message set in ACE: the importer “provides their broker with the seven required product certificate data elements” or “with the Certificate Identifiers to be filed.” The importer owns the data; the broker owns the transmission.
A workable sequence for each regulated SKU:
- Confirm it is regulated. Check the HTS code and applicable rules. CPSC “does not notify the trade of HTS code updates” and points importers to the U.S. International Trade Commission site. Our HTS code guide covers the lookup.
- Get a complete certificate. GCC or CPC, issued by the importer, with all seven elements available.
- Choose Full or Reference. If Reference, open a Product Registry Business Account and enter the certificate.
- Brief your broker before booking. Send the seven elements or the three identifiers with the commercial documents. Your freight forwarder often coordinates the broker; confirm who transmits the CPSC message set.
- Keep records. CPSC can request supporting test records after entry.
This sits alongside other pre-arrival filings. Ocean importers already handle ISF (10+2) through the same broker relationship, so add CPSC data to that checklist.
Low-Value Shipments: No De Minimis Exemption
CPSC’s FAQ is direct: “Any product requiring certification must have an eFiled certificate, regardless of the value of the imported shipment. There is no Section 321 (also known as de minimis) shipment exemption for eFiling.”
The CPSC release frames eFiling against “millions of direct-to-consumer shipments that often bypass traditional retail distribution.” For sellers who ship small parcels from overseas suppliers, a low declared value does not remove the certificate requirement.
Disclaim PGA Message Sets are “not required for any imported shipments, including Section 321 (de minimis) shipments,” though CPSC encourages them “for the benefit of potentially improving their risk score.”
Foreign Trade Zones: January 8, 2027
For goods withdrawn from an FTZ for consumption or warehousing, the importer must submit certificate data when filing the ACE entry, effective January 8, 2027. CPSC’s FAQ calls this a 24-month implementation period and says ACE already accepts the CPSC message set “on a type 06 consumption entry,” including as part of a weekly entry submission. CPSC publishes separate eFiling Guidance for Foreign Trade Zones.
What Happens If Certificate Data Is Missing
As of 2026-10-06, CPSC’s FAQ says: “At this time, CPSC does not intend to request that CBP deny entry of products into the U.S. solely based on failure to eFile certificate data via a Full PGA Message Set or a Reference PGA Message Set.” It adds that CPSC “does not intend initially to have the ACE system send reject messages for missing PGA data, only warning messages.”
That reading is current on the check date and is worded as initial policy, so expect it to change. Warnings are not a safe harbor either. The same answer says CPSC “will continue to enforce certificate requirements for imported consumer products and submit requests to CBP to initiate seizure of non-compliant products,” and intends to adjust an entry line’s risk score based on certificate data, which “should reduce holds and examinations for compliant products.”
Missing data therefore costs you in risk scoring now, even before any reject messages. If a product turns out to be non-compliant after it reaches customers, see handling product recalls.
Common Mistakes
- Assuming eFiling is a children’s-product rule. GCC-covered products need eFiled data too.
- Relying on a low declared value. There is no de minimis exemption.
- Expecting the Product Registry to reach CBP on its own. It does not; the broker must file the identifiers.
- Using a factory certificate with missing fields. If Citation Codes, test dates, or labs are absent, the broker has nothing complete to transmit.
- Treating warnings as permission. Warning-only handling is CPSC’s stated initial approach as of 2026-10-06, and seizure requests continue.
- Forgetting Amazon’s separate document requests. Amazon may ask for compliance documents through its own tools; see Manage Your Compliance. CPSC eFiling is a customs filing, not an Amazon upload.
eFiling Readiness Checklist
- Every regulated SKU mapped to its HTS code and CPSC citations
- A GCC or CPC issued by the importer for each finished product
- All seven data elements on hand, with a Product ID that appears on packaging or invoice
- Each test lab linked to the rules it tested; testing exclusions identified
- Full or Reference method chosen; Registry entries certified if Reference
- Broker confirmed as the party transmitting the CPSC message set
- FTZ entries planned for January 8, 2027
- Test records retained and retrievable on request
For EU-bound inventory, product safety documentation follows a different regime; see our GPSR compliance guide.
Frequently Asked Questions
Does CPSC eFiling apply only to children’s products?
No. It applies to imported finished products that require a certificate under a CPSC rule, ban, standard, or regulation. The final rule’s “finished product certificate” covers both GCCs and CPCs.
Who actually submits the eFiling?
The customs broker transmits the CPSC PGA Message Set in ACE. The importer provides either the seven data elements (Full) or the Certifier ID, Product ID, and Version ID (Reference).
Is a low-value (Section 321) shipment exempt from CPSC eFiling?
No. CPSC’s FAQ says there is no Section 321 (de minimis) exemption and that eFiling applies regardless of shipment value.
Will CBP reject my entry if CPSC data is missing?
As of 2026-10-06, CPSC says it does not initially intend to have ACE send reject messages for missing data, only warnings. CPSC still requests seizures of non-compliant products and uses certificate data in risk scoring.
Does eFiling apply to products made in the United States?
No. CPSC’s July 8, 2026 release states that eFiling does not apply to domestic manufacturers.
Conclusion
CPSC eFiling moves certificate data from something you produce on request to something transmitted at entry, for every regulated import, GCC and CPC alike. Get complete certificates from your suppliers, decide between Full and Reference filing, and give your broker the data before goods ship. The warning-only treatment reflects CPSC’s stated approach as of 2026-10-06; build your process for the day it changes.