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

> Find what each agency needs for a product at US entry: a CPSC certificate (CPC or GCC) with its citations and testing exclusions, or Disclaim A or B with the intended-use code.

Source: https://border.bot/comply
Last updated: 2026-10-21

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.

[Try the free CPSC checker](https://border.bot/tools/cpsc-efiling-checker) · [Read the API guide](https://border.bot/developers)

Reviewed by the border.bot editorial team on 2026-10-21 ([editorial policy](https://border.bot/about/editorial)).

## How Comply works

### 1. Every agency that flags the line

Comply checks the item’s tariff code against [CPSC’s eFiling HTS list](https://border.bot/tools/cpsc-efiling-checker#cpsc-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**

| Item | Detail | Value |
| --- | --- | --- |
| 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**

| Field | Value |
| --- | --- |
| 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**

| Item | Detail | Value |
| --- | --- | --- |
| 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**

| Item | Detail | Value |
| --- | --- | --- |
| 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.

|  | Value | Detail |
| --- | --- | --- |
| Wearing apparel | 403 lines | 319 may need · 84 required |
| Child chairs | 37 lines | 15 may need · 22 required |
| Rugs and carpets | 28 lines | 24 may need · 4 required |
| Furniture | 18 lines | 2 may need · 16 required |
| Mattresses | 13 lines | 7 may need · 6 required |
| Toys | 13 lines | 8 may need · 5 required |
| Imitation jewellery | 11 lines | 11 may need |
| Children’s shoes | 9 lines | 4 may need · 5 required |
| Bicycles | 8 lines | 1 may need · 7 required |
| Infant sleep products | 8 lines | 8 may need |
| Lighters | 7 lines | 2 may need · 5 required |
| Button cell batteries | 5 lines | 5 may need |

Source: [CPSC: Guidance and HTS List for Filing of Electronic Certificates](https://www.cpsc.gov/s3fs-public/CPSCGuidanceHTSListforFilingElectronicCertificates10012026.xlsx)

## 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](https://border.bot/glossary) 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 entry | A spreadsheet of HTS codes | border.bot Comply |
| --- | --- | --- | --- |
| When you know | When the entry is filed | When someone looks it up | When the order or parcel comes in |
| Children or adults | Asked case by case | Not covered | Read from the description |
| Citations | From the importer, if given | Not covered | From CPSC’s citation codes |
| Disclaims | Often skipped | Not covered | A or B with the intended-use code |
| Other agencies | Separately | Not covered | In the same answer |

## What you send, what you get back

**Request**

| Field | Example |
| --- | --- |
| Product | Wooden stacking toy for ages 3+ |
| HTS code | 9503.00.0073 |
| Destination | United States |

**Result**

| Field | Example |
| --- | --- |
| 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.

|  |  |
| --- | --- |
| Input | Up to 100 items, each with a title or description saying what it is and who it is for and, if you have it, its tariff code (without one it is classified first), plus the destination, your reference and, if you like, the agencies to answer for. |
| Output | Per item and agency: file or disclaim, the certificate, each citation with its third-party testing and labelling requirements, testing exemptions, or the disclaim and intended-use code, with flags, category, probability, review flag, reasons and sources. |
| 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, call the REST API, or connect the MCP server to an AI assistant. All three use the same engine and save every result in the workspace.

| Method | Path | What it does |
| --- | --- | --- |
| POST | `/v1/comply` | Check up to 100 items |
| GET | `/v1/comply` | List past checks |

Example request body for `POST https://api.border.bot/v1/comply` (Bearer token from `/oauth2/token`):

```json
{
  "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" }
  ]
}
```

MCP tools at `https://mcp.border.bot/mcp`: `check_agency_filings`. [Developer quickstart](https://border.bot/developers) · [Connect the MCP server](https://border.bot/mcp) · [API reference](https://border.bot/docs/api)

## 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

- [Free CPSC eFiling checker and HTS list](https://border.bot/tools/cpsc-efiling-checker)
- [Restrict: prohibited and restricted goods](https://border.bot/restrict)
- [Classify: the HTS code for every product](https://border.bot/classify)
- [Glossary of customs and trade terms](https://border.bot/glossary)

## Sources

- [CPSC: eFiling Document Library](https://www.cpsc.gov/eFiling-Document-Library)
- [CPSC: Guidance and HTS List for Filing of Electronic Certificates](https://www.cpsc.gov/s3fs-public/CPSCGuidanceHTSListforFilingElectronicCertificates10012026.xlsx)
- [CPSC: Citation, Testing Exclusion, and Disclaim Guidance](https://www.cpsc.gov/s3fs-public/20260928eFilingCitationTestingExclusionDisclaimGuidance.pdf)
- [CPSC: Citation and Testing Exception Codes](https://www.cpsc.gov/s3fs-public/2025-12-18_eFiling-Citation-and-Testing-Exception-Codes.xlsx)
- [CBP: ACE Appendix PGA](https://www.cbp.gov/document/technical-documentation/ace-appendix-pga)

Examples are illustrative unless a source is named. Rules and rates change, so run a check for a current answer.

## Also in border.bot

- [Classify](https://border.bot/classify): The tariff code for the destination, from a description, a product page or a photo.
- [Calculate](https://border.bot/calculate): Duty, import tax and fees, line by line, before the parcel ships.
- [Screen](https://border.bot/screen): Check a person or company against sanctions and denied-party lists.
- [Restrict](https://border.bot/restrict): Goods a country prohibits or restricts, and which agency reviews them.