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CPSC eFiling

CPSC eFiling: what small importers must file, and how.

CPSC’s revised certificate rule took effect on July 8, 2026. When you import a product that needs a CPSC certificate, the certificate data now reaches CBP’s system with the entry — either in full, or as a reference to a certificate stored in CPSC’s Product Registry. Next date: from October 22, 2026, CPSC requires eFiled certificates on international mail shipments too. Here is what that means for a small importer, with the regulation behind each point.

Jul 8, 2026 in effect Oct 22, 2026 mail shipments Jan 8, 2027 Foreign Trade Zones $79 per product

Last updated: September 2026

Who files

The importer — which may be you, not your supplier.

Importer
The importer of record, who may be the owner, the purchaser or an authorized customs broker; a broker acting as importer of record may name the owner, purchaser or consignee as the party responsible for the certificate 16 CFR 1110.3. The importer certifies imported products 16 CFR 1110.7(a).
Mail and low value
For mail and de minimis imports, the importer is a party eligible to make entry — owner, purchaser, consignee or broker. CPSC will not typically treat a consumer buying for personal use as the importer 16 CFR 1110.3.
Marketplace sales
Sales through an online marketplace are commercial transactions, even between consumers, so eFiling applies. Resold and overstock products are covered too CPSC eFiling FAQ.
Made in the U.S.
No eFiling for domestically manufactured products, but the revised certificate content applies to them since July 8, 2026 CPSC update page.
Nothing new to test
CPSC’s Acting Chairman stated that eFiling “creates no new testing, certification, or compliance obligations” — it changes how certificate data you already owe reaches CPSC CPSC news release, July 8, 2026.
What gets filed

Seven data elements, all from your certificate.

The content required by 16 CFR 1110.11, in the order of CPSC’s implementation guide CATAIR v2.5.

  1. 01

    Product identification

    At least one of GTIN, UPC, SKU, model number, serial number, registered number or an alternate ID, with a description that matches the product to the certificate.

  2. 02

    Every applicable rule — and any testing exclusion

    Each rule listed separately, using CPSC’s citation codes; an exclusion is named in place of a test CPSC code guidance.

  3. 03

    The certifier

    Name, street address, city, state or province, country, email and phone.

  4. 04

    The records contact

    The individual — or an always-staffed position — who keeps the test records, with full contact details.

  5. 05

    Date and place of manufacture

    Month and year at least, and the factory’s name, address, email and phone.

  6. 06

    Most recent testing

    The date, and each laboratory or party the certificate relies on, with full contact details. For children’s products, only CPSC-accepted labs qualify.

  7. 07

    Attestation

    The certifier’s statement that the product complies and the data are true. A knowingly false statement is a federal crime, as the attestation itself says.

One certificate describes one product 16 CFR 1110.13(a). Apparel from the same material in several styles, sizes and colors, manufactured and tested together, counts as one product Registry FAQ, Q12.

Two ways to file

Full message set, or Registry plus three identifiers.

Your broker picks the method for each entry line CPSC eFiling FAQ CATAIR.

Full PGA message set

All seven elements, every entry

You send your broker the complete certificate data, and the broker transmits it with each entry. No Product Registry account is needed for this method.

Reference PGA message set

Entered once, referenced each time

The certificate is entered and certified in the Product Registry before entry. Your broker then files only the Certifier ID, Product ID and Version ID. CPSC calls this preferable when you import the same product repeatedly.

The Registry does not talk to CBP’s ACE system. Once a certificate is certified, you must pass the three identifiers to your broker yourself CPSC eFiling FAQ. Our broker-ready sheet does exactly that.

Small parcels and mail

No exemption for low-value shipments.

De minimis
“There is no Section 321 (also known as de minimis) shipment exemption for eFiling.” Any product requiring certification needs an eFiled certificate, regardless of the shipment’s value CPSC eFiling FAQ 16 CFR 1110.13(a)(1).
Mail, since July 8, 2026
For products imported by mail, the certificate data must be entered in the Product Registry before the product arrives in the United States 16 CFR 1110.13(a)(1).
Mail, from Oct. 22, 2026
CBP suspended the de minimis exemption for mail shipments and created a new postal entry process 91 FR 37801. CPSC will require eFiled certificates on mail shipments, through a Full or Reference message set, beginning October 22, 2026, using CBP’s new Entry Type 13 CPSC mail guidance.
Foreign Trade Zones
Products entered from an FTZ for consumption or warehousing: January 8, 2027 90 FR 45917.
If data is missing

Warnings at first. Certificate enforcement goes on.

CPSC says it does not intend, for now, to ask CBP to deny entry solely because certificate data was not eFiled, and that ACE will at first send warning messages, not rejections. In the same answer, it says it will keep enforcing certificate requirements, keep submitting requests to CBP to seize non-compliant products, and adjust each entry line’s risk score using the certificate data it receives — which should mean fewer holds for compliant products CPSC eFiling FAQ.

What the statute says

  • A product not accompanied by a required certificate, or with a false one, shall be refused admission 15 U.S.C. 2066(a)(2).
  • Failing to furnish a required certificate, or issuing a false one, is a prohibited act 15 U.S.C. 2068(a)(6).
  • Missing tracking labels on children’s products fall under both provisions 15 U.S.C. 2063(a)(5).
Product Registry

How data gets into the Registry, and who is responsible.

The rule lets a certifier rely on another party to enter data into the Product Registry; the certifier stays legally responsible for its validity, accuracy, completeness and availability 16 CFR 1110.15. Here is how CPSC’s guide organizes it.

  1. You open the Business Account

    The importer self-registers and designates an employee as Business Account Administrator; that role is reserved to the importer’s own staff CPSC Registry page Registry guide.

  2. You can invite trade partners to a Product Collection

    In CPSC’s terms, trade partners are businesses that help an importer enter or maintain certificate data — customs brokers, manufacturers, testing labs and others. They can be given the Collection Administrator, Editor or Viewer role Registry guide, §2.1.

  3. Data comes in by hand, by CSV file or by API

    Any user with Collection Editor permissions or above can enter certificates one by one or import a CSV file in CPSC’s template CSV guide v3. A user without permission to certify attests that the data entered is accurate and submits it for certification Registry guide, §5.1.

  4. You certify

    The certification stays with the importer, who can delegate it but remains responsible Registry FAQ, Q11. After certifying, there is currently a 48-hour window to edit without creating a new version Registry FAQ, Q7.

What you receive

eFiling-ready in 2 U.S. business days.

$79 per product, or $149 a month for up to 10 new or updated certificates. Written quote, secure card payment, full refund if we are late. 100% in writing — no calls. Pricing details.

  • Rule check with citations, including testing exclusions and the HTS flag check
  • CPC or GCC with every element of 16 CFR 1110.11
  • A CSV import file in CPSC’s official template, with a step-by-step import guide
  • Broker-ready sheet: three identifiers plus the full data set
  • Retest due date for children’s products

What we don’t do

  • Test products — a CPSC-accepted lab does, and we name the tests.
  • File entries with CBP or clear goods — your licensed customs broker does.
  • Classify your goods under the HTS — your broker does; we check the number against CPSC’s list.
  • Give legal advice or guarantee admission of your goods.
  • Log into your Product Registry account or enter data in it — you, your broker or your own Collection Editor imports our file.
  • Certify for you — the certification click stays yours.

CPSC flags about 600 HTS codes that are likely to include regulated products (September 2026 list), and says the list does not cover every code where a certificate may be required CPSC HTS list. Disclaim messages for products that need no certificate are optional, and may help an importer’s risk score CPSC eFiling FAQ.

eFiling questions

Short answers.

Do I need a Product Registry account?

Not if your broker files the Full message set; the Registry is only needed for Reference message sets CPSC eFiling FAQ. If you ship the same products again and again, the Registry saves re-sending seven data elements each time.

What is a Disclaim message?

An optional message for products under a flagged HTS code that need no certificate. Disclaim A: no CPSC rule requiring a certificate applies, or the product is outside CPSC’s jurisdiction. Disclaim B: CPSC is using enforcement discretion — for example, adult clothing exempt from flammability testing CPSC guidance.

Can my supplier’s test reports be used?

Yes, if they meet the component and finished-product testing rules: a certifier may rely on another party’s testing or certification 16 CFR 1110.15. For children’s products the lab must be CPSC-accepted for the tests cited. The certificate must identify every lab it relies on, and CPSC asks that each lab be tied to the rules it tested, component tests included CPSC eFiling FAQ.

Get a quote

Send the product. Get the three identifiers.

We reply within one U.S. business day with the rules that apply and a fixed price. All by email.

Request a quote See the sample file

Sources read September 26, 2026

  1. CPSC final rule, Certificates of Compliance, 90 FR 1800 (Jan. 8, 2025)
  2. CPSC correction to the final rule, 90 FR 45917 (Sept. 24, 2025)
  3. 16 CFR part 1110 — Certificates of Compliance
  4. 16 CFR 1110.3 — Definitions (importer, Product Registry)
  5. 16 CFR 1110.7 — Who must certify
  6. 16 CFR 1110.11 — Certificate content
  7. 16 CFR 1110.13 — Certificate availability and eFiling
  8. 16 CFR 1110.15 — Legal responsibility; reliance on another party
  9. CPSC, eFiling Frequently Asked Questions
  10. CPSC, Update: Certificates of Compliance and eFiling
  11. CPSC news release, eFiling now in effect (July 8, 2026)
  12. CBP, CPSC eFiling Implementation Guide (CATAIR) v2.5
  13. CPSC, eFiling Citation, Testing Exclusion, and Disclaim Guidance v3 (Feb. 27, 2026)
  14. CPSC, Product Registry FAQ v1.4 (updated Apr. 28, 2026)
  15. CPSC, eFiling Product Registry User Guide v3 (Sept. 22, 2025)
  16. CPSC, Product Registry (self-registration)
  17. CPSC, User Guide for CSV Upload v3 (Dec. 2025)
  18. CPSC, Guidance for Mail Shipments on eFiling of Certificates (posted Aug. 31, 2026)
  19. CBP interim final rule, de minimis suspension for mail and new postal entry process, 91 FR 37801 (June 24, 2026)
  20. 15 U.S.C. 2066(a) — Refusal of admission
  21. 15 U.S.C. 2068(a)(6) — Prohibited acts (certificates)
  22. 15 U.S.C. 2063 — Certificates, third-party testing, tracking labels
  23. CPSC, Guidance and HTS List for eFiling (September 2026)