CPSC eFiling: What Importers Must Transmit at Entry Starting July 8, 2026

Starting July 8, 2026, importers of regulated consumer products must transmit certificate of compliance data electronically through CBP's ACE system at the time of entry — not just keep it on file. The model shifts from document-on-demand to proactive data submission, there is no de minimis exemption, and a missing or defective filing can hold your cargo at the port.

For years, importers of consumer products could keep a certificate of compliance on file and produce it only when U.S. Customs and Border Protection (CBP) or the Consumer Product Safety Commission (CPSC) asked for it. That era is ending. Under CPSC's Final Rule amending 16 CFR Part 1110, importers of regulated consumer products must transmit certificate of compliance data electronically — through CBP's Automated Commercial Environment (ACE), at the time of entry — beginning July 8, 2026. The model shifts from document-on-demand to proactive data submission, and a missing or defective filing can hold your cargo at the port.

This article reflects CPSC's Final Rule on Certificates of Compliance (amending 16 CFR Part 1110), published in the Federal Register on January 8, 2025, with enforcement beginning July 8, 2026 — and January 8, 2027 for goods entered from a Foreign Trade Zone for consumption or warehousing. The list of covered products and HTS lines can change; confirm current requirements against CPSC's official eFiling resources, and consult counsel on specific products.

What CPSC eFiling Actually Changes

A Certificate of Compliance is the document certifying that a consumer product meets the CPSC safety rules that apply to it. Children's products require a Children's Product Certificate (CPC) supported by third-party testing; general-use products that fall under a CPSC standard require a General Certificate of Conformity (GCC). Those certificate requirements are not new. What is new is how and when the underlying data reaches the government.

eFiling requires importers to transmit certificate data as a Partner Government Agency (PGA) message set in ACE at the time of entry, so CPSC can screen shipments before release rather than requesting paperwork afterward. CPSC has said it will use algorithms to analyze the filed data and target higher-risk shipments — including low-value shipments that occur frequently.

• Certificate kept on file and produced only if CBP or CPSC requests it|Certificate data transmitted electronically through ACE at the time of entry
• CPSC reviews compliance reactively, after the goods have entered|CPSC screens certificate data up front and can target higher-risk shipments before release
• Low-value Section 321 shipments effectively bypass certificate scrutiny|No de minimis exemption — Section 321 shipments must eFile certificate data too
• Paper or PDF certificate formats held by the importer|Structured PGA message-set data CPSC can analyze at scale

One thing the rule does not do: it does not create new testing obligations, and it does not change which products need a certificate. If a product required a certificate before, it still does. The difference is that the data now moves electronically, at entry, in a structured format CPSC can analyze.

Who and What Is Covered

eFiling applies to finished consumer products subject to a CPSC mandatory standard, rule, ban, or regulation. CPSC has identified over 600 HTS tariff lines within scope — spanning children's goods, apparel, electronics, outdoor gear, and more. Two points catch importers off guard:

• There is no de minimis exemption. Shipments claiming the Section 321 informal-entry exemption — goods valued at $800 or less — must still eFile certificate data. The rule specifically closes the low-value channel so it cannot be used to bypass safety certification.
• Classification drives scope. Whether a product falls within the 600-plus covered HTS lines depends on how it is classified. An accurate HTS classification is what tells you whether an eFiling obligation attaches to a shipment at all.

Not sure which of your products fall within the 600-plus covered HTS lines?

The Two Ways to File

CPSC gives importers two pathways to transmit certificate data through ACE. Which one fits depends on how repetitive your product mix is.

1. Full PGA Message Set

Under the Full PGA Message Set, all required certificate data elements are transmitted through ACE with each entry. This is the direct route and works for importers with varied or infrequent shipments, where reusing a stored certificate would not save much effort.

2. Reference PGA Message Set (CPSC Product Registry)

Under the Reference PGA Message Set, certificate data is entered once into CPSC's Product Registry, which issues a unique reference identifier. That identifier is then transmitted through ACE for each entry line covered by the same certificate — as long as the certificate data remains accurate and applicable. This is built for importers that repeatedly bring in the same certified products and want to avoid re-keying full certificate data on every entry. Typically the importer of record creates the Product Registry account.

The Seven Data Elements You Must Transmit

As of July 8, 2026, a covered entry must include the following certificate data elements, transmitted electronically through ACE:

1. Product identification — such as a GTIN, SKU, UPC, model number, serial number, registered number, or an alternate identifier.
2. The applicable CPSC safety rules or citation codes the product is certified to.
3. Date of manufacture.
4. Place of manufacture — name, full address, and contact information.
5. Date of the most recent compliance testing.
6. Testing laboratory contact information — name, full address, and contact information.
7. Point of contact who maintains the compliance records — name, full address, and contact information.

The revised Part 1110 also requires importers to identify any testing exclusions they rely on. Getting these fields organized now — ideally per product or per certificate — is what makes the transition manageable.

The Dates That Matter

• July 8, 2026 — eFiling is enforced for most imported CPSC-regulated consumer products.
• January 8, 2027 — eFiling is enforced for CPSC-regulated goods entered from a Foreign Trade Zone (FTZ) for consumption or warehousing.

Who Is Responsible When a Broker Files

A customs broker can transmit certificate data on your behalf, but the importer remains legally responsible for its accuracy and completeness. The obligation to certify — and the exposure for a missing, late, or false certificate — stays with the responsible party. If an authorized broker making entry does not have sufficient knowledge of the products to be held responsible for testing and certification, CPSC's guidance allows the broker to identify the owner, purchaser, or consignee who authorized the entry as the party responsible for compliance. Either way, this is not a requirement a broker quietly absorbs; it depends on the importer having certificate data ready and correct.

What Happens If You Do Not Comply

A missing or defective eFiling can flag a shipment as higher-risk and lead to increased inspections, cargo holds, and refused release at the port. Separately from the eFiling mechanics, failing to obtain a required CPC or GCC, or providing a false certificate, may be treated as a violation of the Consumer Product Safety Act — which can expose an importer to civil or criminal penalties, forfeiture, or product recalls. For most importers, the practical risk is operational: shipments that stop at the border because the data was not ready.

How to Prepare Before July 8

Preparation is mostly about data readiness and knowing your scope. A workable sequence:

1. Identify covered products
2. Confirm HTS classification
3. Gather certificate data
4. Choose filing method
5. Test in ACE before July 8

• Run your product catalog against the covered HTS lines to identify which SKUs need a certificate eFiled.
• Confirm HTS classification on covered products so scope decisions are defensible.
• Verify you hold a valid CPC or GCC for each covered product, backed by current testing.
• Assemble the seven data elements per product or per certificate, plus any testing exclusions relied on.
• Decide between the Full PGA Message Set and the CPSC Product Registry reference method for your volume.
• Confirm who transmits the data in ACE — your broker or your team — and put the responsibility in writing.
• Do not assume Section 321 shipments are exempt; include low-value entries in your plan.

This article summarizes CPSC's Certificates of Compliance Final Rule (amending 16 CFR Part 1110) and CPSC's official eFiling guidance. Requirements, covered HTS lines, and effective dates can change — confirm current details on CPSC's eFiling pages before acting.

This article is for general informational purposes only and is not legal advice. Whether a specific product is covered, which certificate applies, and how to file should be reviewed based on the facts of each product and entry.