2026 U.S. CPSC Mandates eFiling

The U.S. Consumer Product Safety Commission (CPSC) issued a final rule on January 8, 2025. Starting July 8, 2026, electronic filing (eFiling) of certificates of conformity is required for imported consumer products regulated by CPSC, including electronics & electrical appliances, adult apparel, all children’s products, toys, and more.

Products imported from foreign free trade zones must comply by January 8, 2027.
This upcoming mandatory electronic filing requirement will change how products enter the U.S. market.

What is CPSC eFiling?

eFiling (Electronic certification) is a process introduced by CPSC that requires importers of regulated U.S. consumer products to submit Certificates of Conformity (COC) electronically.

eFiling not only improves CPSC’s efficiency in overseeing imported goods but also provides a more streamlined and standardized electronic certificate submission process for international trade.

As such, the specific requirements of eFiling have become a key focus for international businesses exporting to the U.S. consumer market.

With CPSC formally approving and implementing the final rule for certificate filing, Chinese exporters shipping consumer products to the U.S. face a new round of compliance challenges.

Scope of CPSC eFiling

CPSC’s new electronic filing system applies to all imported consumer products subject to mandatory safety standards (including low-value shipments).

The new eFiling requirement applies if your product requires testing or certification under any CPSC regulation, including but not limited to:

• Electrical appliances

• Toys

• Apparel and footwear

• Household products

• Youth products

• Furniture

• Seasonal / holiday products

• Textiles meeting safety standards

• Products containing regulated chemicals (e.g., lead, phthalates)

Applies to importers, domestic manufacturers, and private labelers that issue certificates for CPSC-regulated consumer products and substances imported into the U.S. for consumption, storage, or commercial distribution.

CPSC eFiling Content

Importers of regulated products must submit specific data elements electronically (eFiling for Electronic Certificates of Conformity) upon importation, including:

• Product identification information

• Responsible party information for complianCE certification

• List of CPSC consumer product regulations the product is certified to

• Manufacturing date and location of the product

• Date and location of the product’s most recent compliance test

• Contact information of the test record keeper

Using this information, CPSC will improve inspection efficiency and better target high-risk products imported into the U.S.
Electronic filing will also reduce inspection frequency and wait times for compliant importers, rewarding companies with compliance records and enabling faster import clearance.

CPSC eFiling FAQs

Will errors during the voluntary phase of electronic submission or voluntary certificate data filing affect my risk score or cause shipment delays?

While shipments are still subject to routine CPSC inspections, errors during the voluntary eFiling phase will not impact importers’ risk scores or cause shipment delays.
The voluntary phase is designed to support learning and testing without penalizing participants for mistakes.

When certifying a finished product, must importers provide information from all component part test reports?

Yes. Since 2008, detailed information on all testing has been required to support product compliance certification.

Section 14 of the Consumer Product Safety Act (CPSA), 15 U.S.C. § 2063(a) and (g), and Commission regulations (16 CFR Parts 1107, 1109, 1110) require certificates to include specific test information — including testing on component parts when relied upon to demonstrate compliance.

A certificate confirms the product described has been tested to all applicable CPSC regulations and meets those listed.
Although the Commission only requires a certificate for the finished product, all testing supporting compliance must be documented on the certificate.

By law, certificates must state:

• All applicable rules, bans, standards, and regulations

• Most recent test date(s)

• Identification of each test laboratory

Laboratories must be linked to the specific rules/standards they tested, whether testing was performed on finished products or components.
Effective July 8, 2026, revised Part 1110 also requires identification of any relied-upon test exclusions.

Other fields (test URL, report key, test ID) are optional but encouraged.
CPSC may require supporting test records or optional field information on request.

If an importer fails to comply with eFiling, will U.S. Customs and Border Protection (CBP) refuse entry?

Currently, CPSC does not intend to direct CBP to deny entry solely because a party did not electronically submit certificate data via the Full PGA Message Set or Reference PGA Message Set.

Accordingly, CPSC initially does not plan for the ACE system to issue rejection notices for missing PGA data — only warning messages.

However, CPSC will continue enforcing certificate requirements and may request CBP to detain non-compliant products.
Additionally, CPSC plans to adjust risk scores based on certificate data submitted via PGA channels — reducing holds for compliant goods while focusing enforcement on non-compliant products.

CPSC Compliance Recommendations

CPSC eFiling becomes mandatory on July 8, 2026.

The system is currently in a voluntary phase.
Importers and their trade partners are strongly encouraged to participate in the voluntary phase to familiarize themselves with the eFiling system before full implementation.