CPSC eFiling Services

A broker-filed CPSC eFiling service covers the part of certification that happens at the border. We identify which of your HTS lines CPSC flags, map each SKU to the rules that apply to it, and collect the certificate data behind it: product ID, rule citations, certifier, records custodian, date and place of manufacture, date and place of testing with each lab, and the attestation. Then we choose the method per line, a Full PGA message set with all data at entry or a Reference set pointing to a certificate in CPSC's Product Registry, and transmit it in ACE with the entry. After filing we watch the CPSC status on every flagged line, upload documents when CPSC asks, and keep the filed version with the entry record. We do not test products or issue your certificate: the certifier stays responsible for its content under 16 CFR 1110.15.

It depends on SKU count and repetition. The Full message set sends every certificate element with the entry, so it suits low SKU counts, one-off products, and data the broker already holds. The Reference set sends three identifiers, Certifier ID, Product ID and Version ID, pointing to a certificate the importer has already certified in the Product Registry. CPSC's own burden estimate in the final rule is 15.3 seconds per Reference filing against 4.75 minutes per Full filing, and that gap compounds across thousands of lines a month. Methods can be mixed within one entry, so most large importers run Reference for repeat SKUs and Full for new or low-volume items. The trade-off is governance: a Reference filing only works if the Registry record is current, certified, and carries the right Version ID for the goods actually shipped.

Under 16 CFR 1110.11, as amended by the rule published January 8, 2025, each finished product certificate carries seven elements. One, product identification: at least one of GTIN, model number, registered number, serial number, SKU, UPC or another identifier, plus a description. Two, every applicable rule, ban, standard or regulation, listed separately; for toys that means each ASTM F963 section, not F963 as a whole. Three, the certifier's name and full contact details. Four, the records custodian, which may be a staffed position title. Five, date and place of manufacture, month and year at minimum, with the manufacturer's address. Six, the most recent date and place of testing, with each lab relied on, or the testing exclusion claimed instead. Seven, the attestation, which for eFiled certificates is itself a data element. Everything must be in English.

The Product Registry is CPSC's database for the certificates a Reference message set points to. The importer opens a Business Account, and the Certifier ID set at account creation in most cases cannot be changed later, so the legal entity matters from day one. Manufacturers, labs and other trade parties can be invited to enter data, but the finished product certifier remains legally responsible for it. Certificates load one by one, by CSV bulk upload, or by API through a Software Development Account. After a certificate is certified there is a 48-hour window to edit it; after that, a change means a new Version ID, and Version IDs must be unique per Primary Product ID across the whole account. Registry data is not public and attaches only to an entry, never to a manifest. We set the account structure and Version ID rules before the first bulk load.

No. CBP's CSMS #69382435 of July 29, 2026, which superseded the July 8 message, tells filers that ACE will not reject entries for missing CPSC data, and CPSC's FAQ says it does not currently intend to ask CBP to deny entry solely for failure to eFile. That is not a grace period. The certificate requirement is in force, CPSC can answer submitted data with a message reviewing or rejecting it, and a line without data can raise the shipment's risk score and the odds of a hold or exam. Goods not accompanied by a certificate can still be refused admission under 15 U.S.C. 2066(a)(2), and civil penalties currently run up to $120,000 per violation and $17,150,000 for a related series. An accepted entry and a compliant entry are different things, so we treat a missing CPSC line as an open exception, not a pass.

Disclaims are optional, but CPSC encourages them because they tell reviewers why no certificate accompanies a line, which can reduce holds. Disclaim A means no CPSC rule requiring a certificate applies: examples CPSC gives include hats and gloves, sport helmets other than bicycle helmets, component parts for further US manufacturing, and upholstered furniture where 16 CFR 1640 is the only rule. It requires an intended use code. Disclaim B covers CPSC enforcement discretion, which today means adult apparel made only of fabrics exempt under 16 CFR 1610.1(d) and refrigerators bearing a safety certification mark, and it takes intended use code 130.006 and no other. A testing exclusion is different: the certificate is still required and the exclusion code sits inside it. Children's apparel never qualifies for Disclaim B, even when the fabric is exempt.

The certifier for an import is the importer, meaning the importer of record, which the rule says may be an owner, purchaser, or authorized customs broker. Where a broker is the importer of record, it may identify the owner, purchaser or consignee who authorized the entry as the certifier in the CPSC data. If the broker files without naming that party, the preamble to the final rule says CPSC can hold the broker legally responsible, and CBP's implementation guide states that CPSC will then treat the importer of record as the certifier. Consignees may also be held responsible. Suppliers and labs entering Registry data on your behalf do not shift the duty: the finished product certifier stays responsible under 16 CFR 1110.15. We document who is certifier for each account before the first filing, so no line goes out with that field empty.

CPSC-interest HTS lines receive an Under Review status through 1USG messaging. CPSC's clock runs 4 business hours for air and truck and 8 for ocean, rising to 8 and 16 when added risk factors apply, counted 8 a.m. to 4 p.m. port time on federal workdays. If CPSC takes no action, a May Proceed goes out automatically. Otherwise the outcome is Hold Intact, Hold Intact with documents needed through DIS, or an intensive exam, sometimes with documents required, and CPSC Form 354 posts to DIS on holds. A May Proceed can still be followed by an exam at your premises, and it is CBP's release, not the 1USG message, that releases cargo. We watch the status in ABI, cross-check the CPSC Import Shipment Tracking Tool, and upload certificates and test reports the same day a document request posts.

CPSC has published no statistics on post-launch hold causes, so treat this as a list of risk points drawn from the rule and CBP's implementation guide. A children's product certificate filed without the 4-digit CPSC Lab ID, or citing a lab that is not CPSC-accepted. ASTM F963 cited as a whole instead of by section. A testing exclusion claimed without the underlying rule citation. One certificate covering materially different products, since a change in design, factory, or component or paint source needs its own certificate. A place of manufacture that does not match the factory on the commercial invoice. A Reference set pointing to an archived or uncertified Version ID. And the 2026 version updates for durable infant products and toys: goods made after a new effective date need testing to the new ASTM edition, even though the CFR part number stayed the same.

Yes. CPSC's FAQ states there is no Section 321 exemption for eFiling, and the rule text covers products eligible for the de minimis duty exemption. The de minimis route has closed in practice anyway: de minimis has been suspended for all countries since August 29, 2025, and CBP's interim final rule of June 24, 2026 ended Type 86 entries, so non-postal shipments of $800 or less now move on formal or informal entries, which is where the CPSC message set is filed. International mail follows a different path: the certifier must have the data in the Product Registry before the goods arrive. Genuine consumer-to-consumer gifts are out of scope. For marketplace sellers and retail and consumer goods brands shipping many low-value orders, eFiling becomes a volume problem, which is exactly what the Reference set is built for.

Entries for consumption or warehousing from a Foreign Trade Zone become subject to eFiling on January 8, 2027, six months after the July 8, 2026 date for all other entries, as set in the final rule (90 FR 1800) and restated as an applicability date in the September 24, 2025 correction. The data is due with the entry filing, not with the weekly entry summary. CPSC rejected shortcuts such as filing the latest certificate on record for a part number: the certificate must match the goods actually withdrawn, which is hard when zone inventory runs first in, first out. CPSC has signaled that filing at admission on CBP Form 214 could solve this once CBP supports it, but whether that will be ready by January 2027 has not been confirmed. Admitting non-compliant goods to a zone to bring them into compliance is still allowed. Our foreign trade zone consulting team maps admissions to certificates before the date.

Testing labs and inspection firms play a real part in eFiling: they test the product, issue the reports a certificate relies on, and many sell certificate data services or enter data into the Product Registry as invited users. What they cannot do is file in ACE. The CPSC message set is transmitted with the entry through ABI, by the customs broker or a self-filing importer, and a Registry record does nothing until an entry references it. That makes the broker the point where lab data, Registry records and the HTS lines on the entry have to agree. If the Version ID on the entry is wrong, or the lab report covers a different factory than the one on the invoice, the lab's work is sound and the filing still fails. We work with whichever lab you use and treat its reports as inputs to the filing, not a substitute for it.

CPSC eFiling is priced in two parts. The first is setup: mapping your SKUs to CPSC-flagged HTS lines and rules, collecting certificate data, and either building the Product Registry account and bulk load or mapping Full message set fields in our filing system. Setup scales with SKU count and with how clean your supplier data is. The second is per entry: transmitting the CPSC data on each flagged line, handled with the rest of the customs entry, plus hold response work when CPSC asks for documents or an exam. The Reference method keeps the per-line effort low once the Registry is loaded, which is why high-SKU importers usually choose it. We quote setup and per-entry fees separately after a readiness review, so you see the fixed cost before committing and the variable cost per entry after.

Start with an SKU list that includes HTS classification, country of origin, and the product description your invoices use. Then the certificates you hold today: GCCs and CPCs by product, with the rules cited, factory names and addresses, manufacture dates, lab names and CPSC Lab IDs for children's products, and test report numbers. Tell us who should be certifier and records custodian, and whether you already have a Product Registry Business Account. If you import through a Foreign Trade Zone or ship low-value orders, flag that too. With this we map each SKU to Full, Reference or disclaim, list the gaps, and give you a remediation order ranked by volume. Common gaps at this stage are certificates that cite a superseded test edition and certificates that group materially different products, and fixing them before the next entry is the point of the review.