# CPSC eFiling for US imports

> Since 8 July 2026 importers must eFile CPSC certificate data with CBP. Who files, the seven data elements, CPC or GCC, Disclaim A or B, and mail shipments.

Source: https://border.bot/docs/guides/countries/united-states/agencies/cpsc
Last updated: 2026-10-30

> Documentation index: https://border.bot/llms.txt. Every page is Markdown at its URL + `.md`.


Since 8 July 2026, the importer of a product that a CPSC rule, ban, standard or regulation covers must eFile the product's certificate data with CBP when it files the entry, or in CPSC's Product Registry before arrival for goods sent by mail, whatever the shipment's value.

Rules as of 30 October 2026.

> [!IMPORTANT] In effect since 8 July 2026
> Certificate data for imported products under a CPSC rule is eFiled with the entry or entered in the Product Registry; goods entered from a foreign trade zone follow on 8 January 2027.

A certificate of compliance is the certifier's statement, based on testing, that a product meets every CPSC rule that applies to it. eFiling means sending its data elements electronically into ACE instead of keeping the certificate on paper and showing it on request.

## Who must eFile CPSC certificates?

The importer must eFile CPSC certificates for finished products made outside the US that need one: under 16 CFR part 1110 that is the importer of record, who may be the owner, the purchaser or a licensed broker naming the responsible party. CPSC's FAQ says there is no de minimis exemption from eFiling, whatever the shipment's value.

For mail, the importer is whoever is eligible to make entry, such as the owner, purchaser or consignee. CPSC won't typically treat a consumer buying for personal use as the importer, and consumer-to-consumer sales, through a marketplace or otherwise, need no eFiling. US-made products are certified by their manufacturer or private labeler, not eFiled. The other agencies that check imports are in the [agencies overview](https://border.bot/docs/guides/countries/united-states/agencies).

## What goes on a CPC or GCC?

A CPSC certificate is a Children's Product Certificate (CPC) for a product designed or intended primarily for children 12 or younger, tested by a CPSC-accepted third-party laboratory, or a General Certificate of Conformity (GCC) for any other regulated product. Either one carries the same seven data elements, set by 16 CFR 1110.11.

| Element | What it gives |
| --- | --- |
| 1. Product | At least one identifier (GTIN, model, serial, SKU, UPC or another) and a description that matches the product to the certificate |
| 2. Rules | Every rule, ban, standard or regulation the product is certified to, each listed separately |
| 3. Certifier | The importer certifying it, with street address, email and phone |
| 4. Records contact | The person or always-staffed position that keeps the test records |
| 5. Manufacture | Month and year, and the manufacturer's name and full address |
| 6. Testing | The most recent date and place of testing for each rule, with each lab's details |
| 7. Attestation | The certifier's statement that the product complies |

Where testing for a rule is excluded by law or regulation, the certificate names the exclusion instead of a test date and place. Each certificate covers one product and must be produced within 24 hours of a CPSC or CBP request; its records are kept for five years.

## What should be ready before a CPSC-regulated product ships?

A CPSC-regulated product is ready to ship to the US when its certificate exists, its data can reach CBP with the entry, and the importer can produce the test records behind it. For a children's product that means passing tests at a CPSC-accepted lab first; for every product, it means knowing each rule that applies.

- [ ] Every rule the product must meet, with its citation code
- [ ] Test reports for each rule, from a CPSC-accepted lab for a children's product
- [ ] A CPC or GCC with all seven data elements, one per product
- [ ] The data in the Product Registry with its three identifiers sent to the broker, or the full data sent with the entry
- [ ] For mail: the data in the Product Registry before the parcel arrives
- [ ] For flagged products that need no certificate: the disclaim code
- [ ] A records contact who can produce the certificate within 24 hours

## How is the certificate filed with CBP?

CPSC certificate data goes to CBP in one of two message sets. A Full PGA Message Set carries all the certificate data with the entry. A Reference PGA Message Set carries three identifiers (Certifier ID, Product ID, Version ID) pointing to data in CPSC's Product Registry; the importer gives them to its broker.

Mail works differently: the certificate data must be in the Product Registry before the product arrives. From 20 January 2027, 19 CFR 145.12(a)(2)(v) requires a formal entry for mail subject to another government agency's requirements, such as CPSC's (91 FR 66638 set that compliance date), and CBP names its Entry Type 13, filed electronically in ACE, as the informal route for shipments under a partner government agency's jurisdiction. Until then nothing changes and Entry Type 13 is optional; since 22 October 2026 it accepts entries with or without electronic PGA data. [US postal parcels](https://border.bot/docs/guides/postal/united-states) covers the postal routes.

## When is a disclaim filed instead?

A disclaim tells CPSC that a product on a flagged line needs no certificate. Disclaim A means the product isn't CPSC's, or no certificate rule applies; Disclaim B means a rule applies but CPSC's guidance, such as enforcement discretion, waives the data. Disclaims are optional, but CPSC encourages them because they may improve an importer's risk score.

CPSC and CBP flag about 600 HTS lines: CP1 where certificate data may be required and CP2 where it is required. On CPSC's list of 1 October 2026, 430 lines are CP1 and 159 are CP2, most of them clothing. The list isn't exhaustive, so a product under an unflagged line still needs a certificate if a CPSC rule covers it. border.bot's free [CPSC eFiling checker](https://border.bot/tools/cpsc-efiling-checker) shows the whole list and says whether a product needs a CPC, a GCC or a disclaim, with the citations or the intended-use code.

## What happens if the certificate data is missing?

Missing CPSC certificate data doesn't stop an entry on its own, at least at first. CPSC says it doesn't intend to ask CBP to deny entry solely for failure to eFile, and that ACE will initially send warning messages, not rejections. The product must still comply, and its certificate must exist and be produced on request.

The certifier's attestation acknowledges that a knowingly false statement is a federal crime, and the certifier stays responsible for the certificate even when someone else enters the data. To check a catalog before it ships, border.bot's [Comply API](https://border.bot/docs/comply) returns the certificate, citations, lab tests and labeling each item needs, or the disclaim.

## Common questions

### When did CPSC eFiling become mandatory?

On 8 July 2026 for most imported consumer products. Products entered for consumption or warehousing from a foreign trade zone follow on 8 January 2027.

### Is a disclaim required for CPSC?

No. CPSC doesn't require Disclaim PGA Message Sets for any shipment, but encourages them because they can improve the importer's risk score.

### Do low-value parcels need CPSC eFiling?

Yes. CPSC says there is no de minimis exemption: any product requiring a certificate must have it eFiled whatever the shipment's value, and mail shipments use the Product Registry before arrival.

## Sources

- [Certificates of Compliance (final rule)](https://www.federalregister.gov/d/2024-30826), U.S. Consumer Product Safety Commission, Federal Register, 2025-01-08
- [Certificates of Compliance; Correction](https://www.federalregister.gov/d/2025-18521), U.S. Consumer Product Safety Commission, Federal Register, 2025-09-24
- [16 CFR part 1110: Certificates of Compliance](https://www.ecfr.gov/current/title-16/part-1110), eCFR, current as of 2026-10-27
- [16 CFR 1200.2: Definition of children's product](https://www.ecfr.gov/current/title-16/section-1200.2), eCFR, current as of 2026-10-27
- [eFiling Frequently Asked Questions](https://www.cpsc.gov/FAQ/eFiling-Frequently-Asked-Questions-FAQ), U.S. Consumer Product Safety Commission, read 2026-10-30
- [Guidance and HTS List for Filing of Electronic Certificates](https://www.cpsc.gov/s3fs-public/CPSCGuidanceHTSListforFilingElectronicCertificates10012026.xlsx), U.S. Consumer Product Safety Commission, 2026-10-01
- [ACE Agency Tariff Code Reference](https://www.cbp.gov/sites/default/files/2026-03/ace_agency_tariff_codes_04march2026_0.pdf), U.S. Customs and Border Protection, 2026-03-04
- [ACE CATAIR: Participating Government Agencies Message Set](https://www.cbp.gov/sites/default/files/2026-07/26_0706_ace_catair_pga_message_set.pdf), U.S. Customs and Border Protection, 2026-07-01
- [Indefinite Suspension of the De Minimis Exemption for Mail Shipments and New Postal Informal Entry Process](https://www.federalregister.gov/d/2026-12669), Federal Register, 2026-06-24
- [Delayed Compliance Extension for the postal informal entry process (91 FR 66638)](https://www.federalregister.gov/d/2026-21600), Federal Register, 2026-10-22
- [19 CFR 145.12(a)(2): Formal entry of mail](https://www.ecfr.gov/current/title-19/section-145.12), eCFR, current as of 2026-10-27
- [International Mail Entry Type 13 mandatory implementation date extended to Jan. 20, 2027](https://content.govdelivery.com/accounts/USDHSCBP/bulletins/42f29b6), U.S. Customs and Border Protection, 2026-10-14
- [Modification of the Test of the New Electronic Informal Entry Process for Mail](https://www.federalregister.gov/d/2026-21570), Federal Register, 2026-10-22