CPSC Commission Briefing eFiling Guide

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Update time : 2026-10-31

1.CPSC: United States Consumer Product Safety Commission, the enforcement agency responsible for consumer product safety.

2.eFiling: Electronic Filing / Electronic Submission.

3.CPC: Children's Product Certificate.

4.GCC: General Certificate of Conformity, applicable to non-children's products regulated by CPSC laws.

5.cpsia: Consumer Product Safety Improvement Act.

6.ACE: Automated Commercial Environment (CBP Customs System).

7.IOR: Importer of Record / Customs Importer of Record.

Core Definition: What is eFiling? – From Paper Certificates to Digital Filing

eFiling is the United States Consumer Product Safety Commission (CPSC) electronic filing process that requires importers to electronically submit compliance certificates within CBP's Automated Commercial Environment (ACE) system.

Adopting eFiling requires 100% compliance. CPSC will inspect filings at any time, moving away from sample-based enforcement.

Implementation Dates for New Regulations

1.July 8, 2026 – Imported Products (General Cases): Regulated consumer products imported into the United States must complete eFiling in the ACE system.

2.July 8, 2026 – Products Manufactured Domestically in the U.S.: Online submission is currently not required, but compliance certificates must still be retained for verification.

3.January 8, 2027 – Foreign Trade Zone (FTZ) Imported Products: Imported products originating from FTZs receive an additional 6-month transition period.

(Note: This adjustment only changes the submission method of cpsc certificates—transitioning from physical provision upon clearance or waiting for spot checks, to mandatory electronic filing prior to customs clearance. The certification scope of existing products remains unchanged.)

Applicability of eFiling

Scenario	eFiling Applicable?	Notes / Exceptions
De Minimis Duty-Free Goods	Applicable	Must submit PGA Message Set via Entry Type 86 (ET86) customs entry.
International Mail Imports	Applicable (Modified)	Certificate data must be entered into the Product Registry prior to arrival in the U.S.
Foreign Trade Zone (FTZ) Goods	Delayed Application	Effective date deferred to 2027-01-08 (24 months later).
Component Parts	Not Applicable	Certification is required only when sold as an independent finished product.
Replacement Parts	Usually Not Applicable	Unless sold as an independent finished product and regulated by specific rules.
Items for Personal Consumer Use	Excluded	Consumers importing for personal use are generally not considered "importers."

Adult Products: Which Require GCC? (General Use / Non-Children's Products)

Children's Products: Fully Covered Under CPC

Specific product regulatory requirements can be checked using the Regulatory Robot tool at: cpsc.gov/eFiling

eFiling System Data Flow & Options

The CPSC eFiling system is built on the CBP ACE platform. The overall data flow is as follows:

After the importer or authorized party enters certificate data into the CPSC Product Registry, a Unique Reference ID is generated. During customs entry, this is submitted to CPSC via the ACE system using a Reference PGA Message Set. Alternatively, a Full PGA Message Set can be submitted directly all at once during customs entry.

Options for Electronic Submission

Option A: Transmit data directly into the U.S. Customs and Border Protection (CBP) ACE system.

Option B: Enter data into the CPSC official Product Registry first, then provide the certificate identifier to your customs broker.

Frequently Asked Questions (FAQ)

Question	Answer
Is eFiling voluntary or mandatory?	Starting July 8, 2026, eFiling is mandatory for products regulated by CPSC that require certification. Prior to this date, businesses may voluntarily participate in the Beta Pilot project to familiarize themselves with the system.
Is eFiling still required if my product's HTS code is not on the list of ~600 HTS codes published by CPSC?	It may still be required. The list is not exhaustive. If your product is subject to CPSC mandatory standards or is identified as high-risk, eFiling is required even if its HTS code is not listed. Importers are responsible for making their own determination.
Is eFiling required for De Minimis (duty-free goods under $800)?	Yes. De Minimis shipments must submit the CPSC PGA Message Set via Entry Type 86 (ET86). This is a critical component of the eFiling regime designed to eliminate regulatory loopholes for low-value parcels.
Can a third party (such as a testing laboratory) be authorized to handle eFiling?	Yes. The Product Registry supports third-party authorization. Importers may authorize customs brokers, testing laboratories, or other third parties to input data and submit certificates on their behalf. However, ultimate legal liability remains with the importer (the certifier of the finished product).
How often do test reports need to be updated?	It depends on the product type and applicable standards. Generally: (1) Re-testing is required when materials change; (2) Re-testing under new standards is required when standards update; (3) Certain standards require periodic re-evaluation. Establishing a test validity management system is recommended.
What should I do if incorrect certificate information is discovered after submission?	Updated and corrected data should be submitted in the Product Registry as soon as possible, with modification records retained. If the error has already been flagged by CBP/CPSC, proactive communication to explain and provide corrected information is advised.
What are the consequences of failing to complete eFiling as required?	Potential consequences include: (1) CBP entry refusal / customs clearance delays; (2) CPSC administrative penalties; (3) Product recall orders; (4) Legal prosecution. Customs brokers may also be held accountable for failing to submit PGA data.

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Citation Code	Regulation (English)	Regulation Description
1201	16 CFR 1201: Safety Standard for Architectural Glazing Materials	Safety Standard for Architectural Glazing Materials
1202	16 CFR 1202: Safety Standard for Matchbooks	Safety Standard for Matchbooks
1203	16 CFR 1203: Safety Standard for Bicycle Helmets	Safety Standard for Bicycle Helmets
1204	16 CFR 1204: Safety Standard for Omnidirectional Citizens Band Base Station Antennas	Safety Standard for Omnidirectional Citizens Band Base Station Antennas
1205	16 CFR 1205: Safety Standard for Walk-Behind Power Lawn Mowers	Safety Standard for Walk-Behind Power Lawn Mowers
1207	16 CFR 1207: Safety Standard for Swimming Pool Slides	Safety Standard for Swimming Pool Slides
1209	16 CFR 1209: Safety Standard for Cellulose Insulation	Safety Standard for Cellulose Insulation
1210	16 CFR 1210: Safety Standard for Cigarette Lighters	Safety Standard for Cigarette Lighters
1211	16 CFR 1211: Safety Standard for Automatic Residential Garage Door Operators	Safety Standard for Automatic Residential Garage Door Operators
1212	16 CFR 1212: Safety Standard for Multipurpose Lighters	Safety Standard for Multipurpose Lighters
1213	16 CFR 1213: Safety Standard for Entrapment Hazards in Bunk Beds – General Use	Safety Standard for Entrapment Hazards in Bunk Beds – General Use
1261	16 CFR 1261: Safety Standard for Clothing Storage Units	Safety Standard for Clothing Storage Units
1262	16 CFR 1262: Safety Standard for Magnets	Safety Standard for Magnets
1263.3	16 cfr 1263.3: Requirements for Button Cell or Coin Batteries and Consumer Products Containing Such Batteries	Requirements for Button Cell or Coin Batteries and Consumer Products Containing Such Batteries
1263.4	16 CFR 1263.4: Labeling of Button Cell or Coin Battery Packaging	Labeling of Button Cell or Coin Battery Packaging
1270	16 CFR 1270: Safety Standard for Adult Portable Bedrails	Safety Standard for Adult Portable Bedrails
1272	16 CFR 1272: Marking of Toy, Look-Alike, and Imitation Firearms	Marking of Toy, Look-Alike, and Imitation Firearms
1301	16 CFR 1301: Ban of Unstable Refuse Bins	Ban of Unstable Refuse Bins
1303	16 CFR 1303: Ban of Lead-Containing Paint and Certain Consumer Products Bearing Lead-Containing Paint	Ban of Lead-Containing Paint and Certain Consumer Products Bearing Lead-Containing Paint
1304	16 CFR 1304: Ban of Consumer Patching Compounds Containing Respirable Free-Form Asbestos	Ban of Consumer Patching Compounds Containing Respirable Free-Form Asbestos
1305	16 CFR 1305: Ban of Artificial Emberizing Materials (Ash and Embers) Containing Respirable Free-Form Asbestos	Ban of Artificial Emberizing Materials (Ash and Embers) Containing Respirable Free-Form Asbestos
1306	16 CFR 1306: Ban of Hazardous Lawn Darts	Ban of Hazardous Lawn Darts
1420	16 CFR 1420: Requirements for All Terrain Vehicles (ATVs)	Requirements for All Terrain Vehicles (ATVs)
1450	16 CFR 1450: Safety Standard for Swimming Pool and Spa Drain Covers	Safety Standard for Swimming Pool and Spa Drain Covers
1460	16 CFR 1460: Safety Standard for Child-Resistance for Closures on Portable Gas Containers	Safety Standard for Child-Resistance for Closures on Portable Gas Containers
1461	16 CFR 1461: Portable Fuel Container Safety Act Regulation	Portable Fuel Container Safety Act Regulation
1472a	15 USC 1472a: Special Packaging for Liquid Nicotine (CNPPA)	Special Packaging for Liquid Nicotine (CNPPA)
1500.17(a)(13)	16 CFR 1500.17(a)(13): Ban of Candles with Metal-Cored Wicks	Ban of Candles with Metal-Cored Wicks
1507	16 CFR 1507: Fireworks Devices	Fireworks Devices
1512	16 CFR 1512: Requirements for Bicycles	Requirements for Bicycles
1610	16 CFR 1610: Standard for the Flammability of Clothing Textiles	Standard for the Flammability of Clothing Textiles
1611	16 CFR 1611: Standard for the Flammability of Vinyl Plastic Film	Standard for the Flammability of Vinyl Plastic Film
1630	16 CFR 1630: Standard for the Surface Flammability of Carpets And Rugs	Standard for the Surface Flammability of Carpets and Rugs
1631	16 CFR 1631: Standard for the Surface Flammability of Small Carpets and Rugs	Standard for the Surface Flammability of Small Carpets and Rugs
1632	16 CFR 1632: Standard for the Flammability of Mattresses and Mattress Pads	Standard for the Flammability of Mattresses and Mattress Pads
1633	16 CFR 1633: Standard for the Flammability (Open Flame) of Mattress Sets	Standard for the Flammability (Open Flame) of Mattress Sets
1700	16 CFR 1700: Standard for Poison Prevention Packaging	Standard for Poison Prevention Packaging
1750	16 CFR 1750: Standard for Devices to Permit the Opening of Household Refrigerator Doors from the Inside	Standard for Devices to Permit the Opening of Household Refrigerator Doors from the Inside
2056c	15 USC 2056c: Requirements for Sulfur Content in Drywall	Requirements for Sulfur Content in Drywall
2056e	15 USC 2056e: Special Packaging for Button Cell or Coin Battery	Special Packaging for Button Cell or Coin Battery

Citation Code	Regulation (English)	Regulation Description
4.1	ASTM F963: Material quality	Material Quality
4.3.5.1(2)	ASTM F963: Paint and Similar Surface Coating Materials	Paint and Similar Surface Coating Materials
4.3.5.2	ASTM F963: Toy Substrate Materials	Toy Substrate Materials
4.3.6	ASTM F963: Cleanliness of Liquids, Pastes, Putties, Gels, and Powders	Cleanliness of Liquids, Pastes, Putties, Gels, and Powders
4.3.7	ASTM F963: Stuffing Materials	Stuffing Materials
4.5	ASTM F963: Sound Producing Toys	Sound Producing Toys
4.6	ASTM F963: Small Objects	Small Objects
4.7	ASTM F963: Accessible Edges	Accessible Edges
4.8	ASTM F963: Projections (except bath toy projections)	Projections (except bath toy projections)
4.9	ASTM F963: Accessible Points	Accessible Points
4.10	ASTM F963: Wires or Rods	Wires or Rods
4.11	ASTM F963: Nails and Fasteners	Nails and Fasteners
4.12	ASTM F963: Plastic Film	Plastic Film
4.13	ASTM F963: Folding Mechanisms and Hinges	Folding Mechanisms and Hinges
4.14	ASTM F963: Cords, Straps, and Elastics	Cords, Straps, and Elastics
4.15	ASTM F963: Stability and Overload Requirements	Stability and Overload Requirements
4.16	ASTM F963: Confined Spaces	Confined Spaces
4.17	ASTM F963: Wheels, Tires, and Axles	Wheels, Tires, and Axles
4.18	ASTM F963: Holes, Clearances, and Accessibility of Mechanisms	Holes, Clearances, and Accessibility of Mechanisms
4.19	ASTM F963: Simulated Protective Devices	Simulated Protective Devices
4.20.1	ASTM F963: Pacifiers with Rubber Nipples	Pacifiers with Rubber Nipples
4.20.2	ASTM F963: Toy Pacifiers	Toy Pacifiers
4.21	ASTM F963: Projectile Toys	Projectile Toys
4.22	ASTM F963: Teethers and Teething Toys	Teethers and Teething Toys
4.23.1	ASTM F963: Rattles	Rattles
4.24	ASTM F963: Squeeze Toys	Squeeze Toys
4.25	ASTM F963: Battery-Operated Toys	Battery-Operated Toys
4.26	ASTM F963: Toys Intended to Be Attached to a Crib or Playpen	Toys Intended to Be Attached to a Crib or Playpen
4.27	ASTM F963: Stuffed and Beanbag-Type Toys	Stuffed and Beanbag-Type Toys
4.30	ASTM F963: Toy Gun Marking	Toy Gun Marking
4.32	ASTM F963: Certain Toys with Nearly Spherical Ends	Certain Toys with Nearly Spherical Ends
4.35	ASTM F963: Pompoms	Pompoms
4.36	ASTM F963: Hemispheric-Shaped Objects	Hemispheric-Shaped Objects
4.37	ASTM F963: Yo-Yo Elastic Tether Toys	Yo-Yo Elastic Tether Toys
4.38	ASTM F963: Magnets	Magnets
4.39	ASTM F963: Jaw Entrapment in Handles and Steering Wheels	Jaw Entrapment in Handles and Steering Wheels
4.40	ASTM F963: Expanding Materials	Expanding Materials
4.41	ASTM F963: Toy Chests	Toy Chests
5	ASTM F963: Labeling Requirements (as applicable)	Labeling Requirements (as applicable)