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File the right certificate, or the right disclaim, for every item

Since July 2026, goods on CPSC’s eFiling list need a Certificate of Compliance filed with US Customs, or a disclaim saying why not. Comply reads each item’s tariff line and description and tells you, agency by agency, what to file: the certificate and every regulation it cites, or the disclaim and its intended-use code.

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Reviewed by the border.bot editorial team. Updated .

How Comply works

  1. Every agency that flags the line

    Comply checks the item’s tariff code against CPSC’s eFiling HTS list (about 600 lines, each marked “data may be needed” or “required”) and against the customs flags of every other agency, so the FDA, EPA or USDA show up beside CPSC.

    Agencies flagging 9503.00.0073

    CPSC
    On the eFiling list: Toys
    CP2 required
    EPA
    Toxic Substances Control Act data
    EP7 may be

    From CPSC’s eFiling HTS list (October 2026) and CBP’s PGA flags.

  2. Who it’s for decides the rules

    The same tariff line holds a toddler’s T-shirt and an adult’s. A product designed or intended primarily for children 12 and under is certified on a Children’s Product Certificate after third-party testing; other regulated products on a General Certificate of Conformity. Comply reads the description to tell them apart, and says how sure it is.

    Read from the item

    Product
    Wooden stacking toy, painted rings on a peg
    For
    Children aged 3 and up
    Remit
    A consumer product CPSC regulates
    Certificate
    Children’s Product Certificate (CPC)

  3. The certificate, with every citation

    A certificate cites every rule, ban or standard the product is certified to: a CFR part, or each ASTM F963 section for a toy. Comply picks them from CPSC’s own citation codes, adds any testing exclusion that spares a test, and shows how likely each one is to apply.

    Citations for the stacking toy

    4.3.5.1(2)
    ASTM F963: paint and surface coatings
    Cite
    4.7
    ASTM F963: accessible edges
    Cite
    1278a
    Total lead content, children’s products
    Cite
    1303
    Ban of lead-containing paint
    Cite
    1251.2
    Untreated wood: heavy elements
    Exempt

    Illustrative. Codes are CPSC’s citation and testing exception codes.

  4. Or the right disclaim, and why

    Not everything on the list needs a certificate. Disclaim A covers goods no certificate rule applies to, or that aren’t CPSC’s at all; Disclaim B covers goods a rule applies to but CPSC waives by guidance, such as exempt adult clothing. Comply names the disclaim and the intended-use code it is filed with.

    Two disclaims

    Adult knit gloves
    On the list, no certificate rule applies
    A · 130.XXX
    Adult cotton shirt
    16 CFR 1610 applies, certificate waived
    B · 130.006

    From CPSC’s Citation, Testing Exclusion, and Disclaim Guidance.

A held parcel costs more than the filing

Without the certificate data or a valid disclaim, CPSC-regulated goods can be held at the border, refused or destroyed, and penalties can follow. Working out what each item needs by hand, for every SKU and every shipment, doesn’t scale.

  • Know at acceptance, not at the border

    Check items when an order is taken or a parcel is accepted, so the ones that need a certificate are stopped before they ship and the rest flow through.

  • The right certificate, cited right

    CPC or GCC, with every regulation from CPSC’s own citation codes and any testing exclusion that applies, ready for your broker or the Product Registry.

  • Disclaims you can stand behind

    Disclaim A or B with its intended-use code and the reason, so a disclaim is a decision on record rather than a guess that lowers your risk score.

  • Every agency, not just CPSC

    The same check lists the FDA, EPA, USDA and every other agency that flags the line, so one answer covers what the entry needs.

What’s on CPSC’s list

CPSC’s eFiling HTS list flags 589 tariff lines. Clothing is two thirds of them, and children’s furniture, rugs, mattresses and toys most of the rest.

Source: CPSC: Guidance and HTS List for Filing of Electronic Certificates (opens in a new tab)

  1. Wearing apparel403 lines319 may need · 84 required
  2. Child chairs37 lines15 may need · 22 required
  3. Rugs and carpets28 lines24 may need · 4 required
  4. Furniture18 lines2 may need · 16 required
  5. Mattresses13 lines7 may need · 6 required
  6. Toys13 lines8 may need · 5 required
  7. Imitation jewellery11 lines11 may need
  8. Children’s shoes9 lines4 may need · 5 required
  9. Bicycles8 lines1 may need · 7 required
  10. Infant sleep products8 lines8 may need
  11. Lighters7 lines2 may need · 5 required
  12. Button cell batteries5 lines5 may need

Who uses Comply

  • Posts and carriers

    Run each item through Comply at acceptance: the ones needing a certificate are held for it, and the rest move on. Postal shipments now have their own entry type for CPSC filings.

  • Marketplaces

    Tell sellers which listings need a certificate before they ship to the US, and collect it at listing time.

  • Brokers and 3PLs

    Work out the PGA message set for every line of an entry in one request, with the citations and disclaims to file.

  • Brands and importers

    Check the catalogue once, find the products that need a CPC or GCC, and see which tests each certificate must rest on.

How CPSC eFiling works

What changed in 2026

Certificates of Compliance have been required for regulated consumer products for years, but they were kept on paper and shown on request. Since July 2026 the certificate data must be filed electronically: with the customs entry as a CPSC PGA message set, or ahead of time in CPSC’s Product Registry. CPSC also published guidance for mail shipments, which use their own entry type.

Which products are covered

Any product subject to a CPSC rule, ban, standard or regulation needs a certificate, whatever its tariff code. To focus enforcement, CPSC and CBP flag about 600 tariff lines: CP1 where certificate data may be needed, CP2 where it is required. Wearing apparel is the largest group, followed by children’s chairs, rugs, furniture, mattresses and toys.

Children’s Product Certificate or General Certificate of Conformity

A children’s product, designed or intended primarily for children 12 and under, is certified on a Children’s Product Certificate after testing by a CPSC-accepted third-party lab. Other regulated products are certified on a General Certificate of Conformity, which can rest on a reasonable testing programme. Each certificate cites every rule it is certified to, by its citation code.

When a disclaim is filed instead

A flagged item that needs no certificate is disclaimed. Disclaim A says no certificate rule applies, or the product isn’t CPSC’s to regulate (adult hats and gloves, collectibles for adults, medical or industrial products). Disclaim B says a rule applies but CPSC exercises enforcement discretion, as for adult clothing exempt from the flammability standard, and is filed with intended use 130.006.

Filing a disclaim voluntarily, even where it isn’t required, can lower an importer’s risk score in CPSC’s system.

Three ways to handle eFiling

Broker decides at entryA spreadsheet of HTS codesborder.bot Comply
When you knowWhen the entry is filedWhen someone looks it upWhen the order or parcel comes in
Children or adultsAsked case by caseNot coveredRead from the description
CitationsFrom the importer, if givenNot coveredFrom CPSC’s citation codes
DisclaimsOften skippedNot coveredA or B with the intended-use code
Other agenciesSeparatelyNot coveredIn the same answer

What you send, what you get back

Request

Product
Wooden stacking toy for ages 3+
HTS code
9503.00.0073
Destination
United States

Result

CPSC
File a CPC
Cite
4.3.5.1(2), 4.7, 1278a, 1303
Lab testing
4.3.5.1(2), 4.7, 1303 by a CPSC-accepted lab
Testing exemption
1251.2 for untreated wood
EPA
EP7: data may be required

Illustrative example.

  • Agencies

    CPSC eFiling decided in full; every other US agency that flags the line (FDA, EPA, USDA, Fish and Wildlife and more) listed with what its data needs.

  • Rules

    CPSC’s eFiling HTS list, citation and testing exception codes and disclaim guidance, and the CFR’s testing (16 CFR 1112.15) and labelling sections, imported as published and kept up to date.

  • Decisions

    Whether a product is CPSC’s, whether it is for children and which rules apply are decided per product, with a probability and a review threshold you set.

  • Evidence

    Every check is kept with its answers, and can be listed again from the API or the dashboard.

  • In classification

    Every code Classify returns lists the agencies that flag it, so you know when to run Comply.

With or without code

Run single checks and CSV uploads in the dashboard with no integration work, call the REST API from your own systems, or connect the MCP server to an AI assistant. All three use the same engine and save every result in your workspace.

REST API

  • POST/v1/complyCheck up to 100 items
  • GET/v1/complyList past checks

MCP tools

check_agency_filings in Claude, ChatGPT, Cursor and other MCP clients.

Developer quickstartConnect the MCP serverAPI reference (opens in a new tab)

POST /v1/comply
curl https://api.border.bot/v1/comply \
  -H "Authorization: Bearer $BORDERBOT_TOKEN" \
  -H "Content-Type: application/json" \
  -d '{
  "destinationCountry": "US",
  "agencies": ["CPSC"],
  "items": [
    { "sku": "TOY-STACK-01",
      "title": "Wooden stacking toy for ages 3+",
      "hsCode": "9503.00.0073" },
    { "sku": "BEAR-01",
      "title": "Plush teddy bear",
      "description": "Polyester fill, for toddlers" }
  ]
}'

Questions about Comply

What is CPSC eFiling?

The electronic filing of Certificates of Compliance with US Customs for products the Consumer Product Safety Commission regulates, mandatory since July 2026: the certificate data goes with the entry, or into CPSC’s Product Registry, or a disclaim is filed.

Which products need a certificate?

Any product subject to a CPSC rule, ban or standard, such as toys and other children’s products, clothing, mattresses, bicycle helmets, lighters and some rugs. CPSC’s eFiling HTS list names the tariff lines it flags, but a product under another line can still need one.

What is the difference between Disclaim A and Disclaim B?

Disclaim A: the product is on the list but no certificate rule applies, or it isn’t CPSC’s to regulate. Disclaim B: a rule applies, but CPSC doesn’t require a certificate by guidance, such as adult clothing exempt from the flammability standard. B is filed with intended use 130.006.

Does Comply file anything with Customs?

No. It tells you what to file: your broker sends the PGA message set or disclaim with the entry, or you register the certificate in CPSC’s Product Registry.

Where do the rules come from?

From CPSC’s eFiling document library: the HTS list, the citation and testing exception codes and the disclaim guidance, imported as CPSC publishes them; from the Code of Federal Regulations, which rules need testing by a CPSC-accepted lab (16 CFR 1112.15) and each rule’s labelling sections; plus CBP’s partner agency flags for every other agency. Every answer links to its source.

How sure is the answer?

The rules are CPSC’s; whether one applies to your product is decided from its description and comes with a probability. Answers below the review threshold are marked for a person to check.

Does it cover the FDA and other agencies?

Every agency that flags the line is listed with what its data needs. CPSC is decided in full first; other agencies’ rules are added the same way.

Does it say which tests and labels a product needs?

Yes. Each regulation cited comes with whether a children’s product is tested to it by a CPSC-accepted third-party lab (the rules and test methods in 16 CFR 1112.15), with a few labs CPSC accepts for each test, those in the country it’s made in first, and the rule’s own labelling sections with the wording they require, word for word, and where it goes. A children’s product certificate also gets the tracking label.

Do I need the HTS code?

It gives the most precise answer, but no: an item without one is classified for the destination first and charged as a classification.

Can I check a whole order or catalogue?

Yes. Send up to 100 items per request through the API, or use the dashboard and the MCP server; every check is kept as evidence.

Does Classify know about eFiling too?

Every code Classify returns lists the agencies that flag it, including CPSC’s eFiling flags, so you know which products to run through Comply.

Further reading

Sources

Examples on this page are illustrative unless a source is named. Rules and rates change, so run a check for a current answer. This page was reviewed by the border.bot editorial team on . How we check our pages.

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