CPSC eFiling Requirements for U.S. Importers
CPSC eFiling is now effective for most imported finished products that require a certificate of compliance. Importers must determine which products are covered, assemble accurate certificate data, and transmit the required information through CBP’s Automated Commercial Environment at entry.
This guide explains the July 8, 2026 effective date, who CPSC treats as the importer, when a product requires eFiling, the Full and Reference PGA filing options, the information needed from manufacturers and laboratories, and the steps to complete before a customs broker files the entry.
What CPSC eFiling requires as of July 2026
The CPSC Certificates of Compliance final rule revised 16 CFR part 1110. For covered imports, required finished-product certificate data must be electronically filed through the CPSC Partner Government Agency message set in CBP ACE at the time of entry.
Most covered imports are now within the eFiling requirement
The main effective date applies to CPSC-regulated consumer products and substances subject to the final rule that are required to be certified, except covered merchandise entered from an FTZ for consumption or warehousing.
Certificate data is tied to the import entry process
The final rule requires the finished-product certificate data to be eFiled when the CBP entry is filed, or when the entry and entry summary are filed together. Importers should have the applicable data or Product Registry identifiers ready before the broker reaches that stage.
Not every imported product requires CPSC eFiling
eFiling applies when the imported finished product is subject to a CPSC-enforced rule, ban, standard, or regulation that requires certification. A product outside that certificate requirement does not become certifiable merely because it is imported.
Who is responsible for CPSC certificate data
The entity filing an entry, the customs broker transmitting the PGA data, and the finished-product certifier may have different operational roles. Those roles should be documented before product and testing data is handed to the broker.
CPSC generally starts with the party eligible to make entry
For eFiling purposes, CPSC describes the importer as the Importer of Record eligible to make entry for the imported finished products. That party may be an owner, purchaser, or authorized customs broker.
A broker may identify the owner, purchaser, or consignee as the certifier
If an authorized broker lacks sufficient product knowledge to be responsible for testing and certification, the broker may identify the owner, purchaser, or consignee that authorized entry as the party responsible for CPSC certificate compliance.
The broker still needs the correct filing package
The responsible certifier should provide either the complete data needed for a Full PGA Message Set or the correct Certifier ID, Product ID, and Version ID for a Reference PGA Message Set. A broker cannot create missing laboratory, testing, manufacturing, or citation information.
How to determine whether an imported product requires eFiling
Applicability is a product-specific compliance question. Review the finished product, applicable CPSC rules, the date of manufacture, any certification requirement, and the records supporting the certificate before preparing an eFiling record.
Is the finished product regulated under a law enforced by CPSC?
Begin with the product itself, its intended use, age grading, materials, design, and applicable safety rules. Product classification should not be based on a keyword, marketplace category, or HTS code alone.
Does an applicable rule require a certificate of compliance?
The eFiling obligation follows the certificate requirement. If the finished product must be certified under an applicable rule, ban, standard, or regulation, its certificate data generally must be eFiled when imported for consumption or warehousing.
Can the certificate data be supported by current product and test records?
Confirm that product identifiers, applicable citations, manufacturing information, test dates, testing laboratories, exclusions, and contact details agree with the records used to certify the finished product. Do not invent values to complete a filing.
The seven data categories used in a Full PGA Message Set
CPSC’s importer FAQ identifies seven required product-certificate data categories for the Full PGA route. Each category may contain several individual fields, codes, addresses, relationships, or conditional values in the official technical specification.
Identify the finished product covered by the certificate
Use a supported identifier that accurately connects the imported product to the certificate record, such as a GTIN, model number, registered number, serial number, SKU, UPC, or supported alternate identifier.
State the applicable rules, bans, standards, and regulations
The certificate must separately identify the requirements to which the finished product is being certified. If a permitted testing exclusion is relied upon, the applicable exclusion information must also be supported and reported.
Report when the finished product was manufactured
The certificate requires the manufacturing date at the level specified by the rule. For manufacturing runs spanning multiple days, review the current official instructions for the date value that must be reported.
Identify where the product was manufactured, produced, or assembled
Prepare the manufacturer’s required name, physical address, geographic details, and contact information. Use the actual manufacturing location supported by the product records.
Report the testing date supporting certification
The test information should reflect the records relied upon for the certificate. Where component-part testing supports certification, the related testing details must be addressed in accordance with current CPSC requirements.
Connect each laboratory to the testing it performed
Identify the testing laboratory and ensure its details correspond to the rules or requirements it tested. A laboratory name alone may not satisfy the complete field structure used by the Product Registry or PGA filing.
Provide a responsive records contact
The contact responsible for maintaining supporting records should have complete and current details. The final certificate rule permits a position title only when the position remains staffed and responsive to CPSC requests.
Full PGA Message Set or Reference PGA Message Set
Both routes transmit CPSC certificate information through CBP ACE, but they organize the data differently. Select the workflow with the customs broker and responsible certifier before preparing files or assigning internal product IDs.
Send the complete certificate data with the entry filing
The importer gives the broker the seven required product-certificate data categories and the broker files them in the CPSC PGA Message Set. The CPSC Product Registry is not required for this route.
Often relevant when: certificate data will be supplied directly for the entry and the importer does not need to reference a stored Product Registry record.
Store the certificate in the Product Registry and file its identifiers
The importer first enters and certifies the product certificate data in the Product Registry. The broker then files the Certifier ID, Product ID, and Version ID needed to reference that certificate record.
Often relevant when: the same unchanged certificate will support repeated imports and the importer wants a reusable Product Registry record.
The Product Registry does not transmit the entry to CBP
CPSC describes the Product Registry as a stand-alone certificate-data repository. After a certificate is stored and certified, the importer must still provide the correct Certificate Identifiers to the broker or other filing party for the Reference PGA Message Set.
Manual entry, CSV bulk upload, or API integration
Importers using the Reference PGA route can prepare Product Registry certificate records through the user interface or one of the bulk-upload methods. The practical choice depends on product volume, data quality, repeat imports, and available technical resources.
Enter one certificate through the Product Registry interface
Manual entry may suit a small number of certificates, but each record still requires complete and consistent product, citation, manufacturing, testing, laboratory, and contact information.
Prepare certificate records in the official CSV structure
The CSV route supports bulk preparation but does not remove field requirements. Headers, identifiers, conditional fields, repeated values, and row relationships must match the current CPSC template and upload instructions.
Transmit certificate data from an internal system
The API route may suit larger or recurring workflows, but it requires development, authentication, field mapping, error handling, version control, and monitoring against the current CPSC API specification.
Requirements that are easy to overlook
Shipment value, resale status, entry channel, or use of a Foreign Trade Zone can change the filing workflow, but those facts do not automatically remove an underlying certificate requirement.
Low shipment value is not an eFiling exemption
CPSC states that any product requiring certification must have eFiled certificate data regardless of the imported shipment’s value. There is no Section 321 exemption from the certificate eFiling requirement.
Commercial resale does not automatically remove the requirement
CPSC states that covered used products manufactured after the applicable rule took effect, as well as regulated resold or overstock products distributed in commerce, may remain subject to testing, certification, and eFiling requirements.
Product Registry entry may be required before arrival
For covered finished products imported by mail, the final rule requires the finished-product certifier to enter the required certificate data into the CPSC Product Registry before the product arrives in the United States.
Covered FTZ merchandise has a separate effective date
The eFiling effective date for covered merchandise entered from an FTZ for consumption or warehousing is January 8, 2027. The certificate data is submitted with the applicable ACE entry when merchandise is withdrawn from the FTZ.
A Disclaim message is encouraged in some cases, not required
CPSC states that Disclaim PGA Message Sets are not mandatory. The agency encourages appropriate disclaim filings because the additional information may help explain why no certificate accompanies a shipment and may improve risk scoring.
A warning message does not make certificate compliance optional
CPSC says it does not initially intend to request entry denial solely for missing eFiled data and expects warning rather than reject messages for missing PGA data. The agency also states that certificate requirements remain enforceable and non-compliant products may still face seizure or other action.
What to complete before the customs entry is filed
Treat eFiling as a data-readiness process that begins before the shipment reaches the port. The broker’s transmission is the final operational step, not the point at which missing product and testing information should first be discovered.
List the finished products, variants, and identifiers being imported
Separate products that may rely on different certificates, citations, manufacturing locations, test reports, laboratories, or dates.
Confirm which products require CPSC certification
Review current CPSC rules and product facts. Record the basis for the determination and escalate unclear cases to qualified compliance or legal professionals.
Collect certificates, test reports, manufacturer details, and laboratory data
Resolve conflicts between source documents before mapping fields. Missing evidence cannot be repaired by adding a plausible value to a spreadsheet.
Agree on Full or Reference PGA filing with the broker
Define who creates the certificate record, who certifies it, who supplies the data or Certificate Identifiers, and who transmits the PGA Message Set in ACE.
Validate fields before Product Registry upload or broker handoff
Check headers, identifiers, dates, addresses, citation codes, testing relationships, conditional requirements, duplicates, and missing values against current official documents.
Review certificate records before reusing them
Confirm that the product, version, citations, manufacturing data, test information, laboratories, contacts, and official technical requirements remain unchanged.
Problems that can delay a clean eFiling workflow
Many filing problems begin upstream: incomplete source documents, unclear responsibility, inconsistent product IDs, or data assembled in a format that does not match the official Product Registry structure.
Treating an HTS flag as the final certification decision
HTS and CPSC code lists can support review, but the product’s actual characteristics and applicable CPSC requirements control the certification analysis.
Assuming the broker owns the underlying certificate data
The responsible certifier must be able to support the product, testing, manufacturing, citation, laboratory, and contact information supplied for filing.
Expecting Product Registry records to reach ACE automatically
The Product Registry does not communicate with ACE. The correct Certificate Identifiers still must be transmitted in the Reference PGA Message Set.
Using incomplete or inconsistent manufacturer and laboratory records
Names, addresses, countries, contacts, dates, and relationships should be normalized without changing the factual content of the supporting records.
Reusing a certificate after the underlying details changed
A reusable Product Registry certificate should only be referenced while its product and certificate details remain identical to the imported product.
Building a CSV from an outdated template or field list
CPSC may update its template, user guide, code lists, and API specification. Compare every working file with the current official Document Library.
Continue with the guide for your next task
Use the requirements guide to establish scope and responsibility, then move to the detailed page for product applicability, Product Registry setup, CSV preparation, field review, error correction, seller workflows, or Foreign Trade Zones.
CPSC eFiling Resource Center for U.S. Importers
Open the central hub for implementation dates, filing options, official sources, the application, and every Registry Intelligence eFiling guide.
Which Products Require CPSC eFiling?
Review how the product’s certification requirement determines whether eFiling applies.
How to Use the CPSC Product Registry
Understand Business Accounts, Product Collections, certificate records, identifiers, privacy settings, and broker handoff.
CPSC eFiling CSV Template: How to Prepare a Bulk Upload File
Prepare multiple Product Registry certificate records using the current CSV structure.
CPSC eFiling CSV Upload Errors and How to Fix Them
Identify formatting, field, relationship, identifier, and row-level issues before another upload attempt.
CPSC eFiling Data Elements and CSV Field Requirements
Review the information needed for products, citations, manufacturing, testing, laboratories, and records contacts.
CPSC eFiling for Amazon and Private-Label Sellers
Connect supplier records, private-label products, certificates, testing data, importer roles, and recurring imports.
CPSC eFiling Requirements for Foreign Trade Zones
Prepare for the separate effective date and the entry workflow for covered merchandise withdrawn from an FTZ.
Verify requirements against current CPSC and Federal Register materials
CPSC can update templates, code lists, user guides, FAQs, and technical specifications. Use the controlling rule and the latest official documents before making a product-specific decision or submitting certificate data.
Certificates of Compliance, 90 FR 1800
The final rule revising 16 CFR part 1110 and implementing certificate eFiling for covered imports.
eFiling Resources for Importers
Official guidance on importer roles, responsible certifiers, accounts, and implementation materials.
Does eFiling Apply to Me?
Official links for researching regulated products, testing, certification, labeling, and small-batch questions.
CPSC Product Registry
Official account registration, system information, limitations, and access to Product Registry resources.
eFiling Document Library
Current guides, CSV template, CSV upload instructions, API specification, CATAIR materials, code lists, and FTZ guidance.
eFiling Frequently Asked Questions
Official answers covering data, filing routes, Product Registry use, enforcement, special shipment types, and support.
Questions U.S. importers ask before filing
These answers summarize the current federal framework. Use official requirements and the facts for the specific product and shipment before making a compliance decision.
When did CPSC eFiling become mandatory?
July 8, 2026 is the effective date for most imported products subject to the final rule and required to be certified. Covered merchandise entered from an FTZ for consumption or warehousing has a January 8, 2027 effective date.
Does every U.S. importer need to eFile with CPSC?
No. The requirement applies to imported finished products that must be certified under a consumer product safety rule or similar rule, ban, standard, or regulation enforced by CPSC.
Must every importer use the CPSC Product Registry?
No. The Product Registry supports the Reference PGA route. An importer using a Full PGA Message Set may provide all required certificate data for the entry without using the Product Registry.
Can the customs broker prepare all certificate information?
The broker can transmit the filing, but the responsible certifier must supply accurate and supportable certificate data or the correct Product Registry identifiers. A broker should not guess missing compliance information.
Can one Product Registry certificate be reused?
Yes, when the product certificate details remain identical. If the product or certificate data changes, review whether the record or version must be updated before it is referenced again.
Are de minimis shipments exempt from CPSC eFiling?
No. CPSC states that any product requiring certification must have eFiled certificate data regardless of shipment value.
Does the Registry Intelligence application submit data to CPSC or CBP?
No. The application is designed to check, map, and prepare user-supplied data for a Product Registry-formatted CSV. It does not make legal applicability decisions, create missing evidence, transmit an ACE entry, or guarantee government acceptance.
Check certificate data before Product Registry upload
Upload one or several supported source files, confirm the field mapping, identify missing or inconsistent information, and prepare a CPSC Product Registry-formatted CSV from the rows that are ready.
Use official sources for final product and filing decisions
Registry Intelligence is not affiliated with, endorsed by, or operated by the U.S. Consumer Product Safety Commission or U.S. Customs and Border Protection. This page provides educational and data-preparation information, not legal advice, customs brokerage, product testing, certification, or a government filing service. Official rules, current agency guidance, technical documents, and product-specific facts remain controlling.