The US eFiling Amazon and Temu Sellers Must Complete Electronic

With less than three weeks remaining until July 8, 2026, the US market is about to welcome a major compliance update. If you are operating on Amazon US, TikTok Shop, independent websites, or selling products to the US via overseas warehouses, bookmarking this article is highly recommended.

Starting July 8, the US Consumer Product Safety Commission (CPSC) will officially implement the eFiling electronic filing system. In the future, simply holding a CPC or gcc certificate will no longer be enough. Relevant product information must be entered into the US regulatory system in advance and electronically verified during the customs clearance process. For cross-border sellers, this will become one of the most critical compliance policies to watch in the US market in 2026.

What is CPSC eFiling?

Simply put, CPSC eFiling is not a new certification. It is a new electronic filing mechanism. In the past, importers usually needed to retain product test reports and CPC or gcc certificates for subsequent random checks by US regulatory authorities.

Starting July 8, 2026, when certain consumer goods enter the United States, relevant compliance information must be submitted to US regulatory agencies in advance through an electronic system.

The regulatory approach will gradually upgrade from traditional "certificate retention for inspection" to "electronic filing + risk identification." For compliant products, the future customs clearance process may become more efficient. Conversely, products with incomplete information, expired certificates, or missing data may face a higher risk of inspection.

What are the Core Differences Before and After eFiling Implementation?

Following the implementation of eFiling, US consumer product import regulation will progressively evolve from the traditional "data retention + post-import inspection" model to a "data filing + system pre-verification" framework. Overall, the key change is not merely digitization, but the shifting of the regulatory checkpoint forward and the upgrading of the risk identification mechanism.

The core comparison between the old and new models is outlined below:

Regulatory Logic

• Before Implementation (Old Model): Primarily focused on random inspections after customs clearance.

• After Implementation (New Model): Prioritizes filing and verification first, releasing goods only after approval.

Documentation Requirements

• Before Implementation (Old Model): Only required retaining certificates/reports.

• After Implementation (New Model): Requires retaining certificates/reports PLUS the mandatory online submission of standardized electronic data.

Shipment Value Rules

• Before Implementation (Old Model): Shipments under $800 and small parcels were commonly exempt from verification.

• After Implementation (New Model): No exemptions; regulated product categories are managed uniformly regardless of value.

Certificate Management

• Before Implementation (Old Model): Reusing or mixing certificates across products was relatively common.

• After Implementation (New Model): Automated system verification; non-compliant submissions fail immediately.

Inspection Methods

• Before Implementation (Old Model): Manual random checks with high unpredictability.

• After Implementation (New Model): Data-driven risk control with full-link traceability.

Consequences of Non-Compliance

• Before Implementation (Old Model): Primarily focused on corrections or fines.

• After Implementation (New Model): Goods that fail to complete filing as required may face inspections, delayed release, detention, or other regulatory enforcement measures, depending on the product category, filing status, and customs enforcement discretion.

Brief Summary:

• Higher Entry Barriers: Shifted to a "file first, clear customs later" system where documentation must be submitted upfront.

• End of the Small Parcel Dividend: For small parcel sellers who previously relied heavily on the Section 321 entry mode, close attention must now be paid to eFiling requirements. Product compliance costs and data management standards will further increase.

• Tightened Compliance Controls: Activities such as certificate reuse and mismatched information will be intercepted directly by the system.

When Will It Be Implemented?

According to the 16 CFR Part 1110 regulation published in the US Federal Register, eFiling will be implemented in two phases.

• Phase One: July 8, 2026
  Applies to general imported consumer products.

• Phase Two: January 8, 2027
  Applies to relevant products entering via US Foreign Trade Zones (FTZ).

Please Note: For products subject to filing, there is no shipment value exemption. Even for the familiar Section 321 tax-exempt parcels (under $800), electronic filing must still be completed if the product falls within the regulated scope.

Which Products Fall Within the Scope of eFiling?

Starting July 8, 2026, any imported consumer product that is required by law to issue a CPC or GCC certificate must submit the corresponding certificate data through the ACE system (eFiling) when importing into the United States. Goods failing to submit the required certificate data may face risks such as inspections, clearance delays, or even entry refusal.

CPC (Children's Product Certificate)

• Scope of Application: Products intended primarily for children 12 years of age and younger.

• Typical Products: Toys, baby products, children's clothing, children's furniture, children's tents, children's accessories, etc.

• Compliance Requirements: Must be tested based on applicable regulations, and test reports must be issued by a CPSC-accepted laboratory; a cpc certificate must be issued; products included in the eFiling scope must complete electronic filing as required.

GCC (General Certificate of Conformity)

• Scope of Application: General use consumer products (General Use Products).

• Typical Products: Luminaires, power adapters, certain furniture, household goods, outdoor products, and other regulated consumer products.

• Compliance Requirements: Must complete a conformity assessment and issue a GCC based on applicable regulations; certain products require supporting test reports; products included in the eFiling scope must complete electronic filing as required.

Non-CPSC Regulated Products

• Scope of Application: Products that do not fall under the regulatory jurisdiction of the CPSC.

• Typical Products: Typical industrial equipment, pure B2B specialized equipment, and certain raw materials.

• Compliance Requirements: Generally do not require a CPC or GCC; whether eFiling is required depends on whether the product falls within a specific filing scope mandated by other regulations.

Naturally, not all products require filing. If a product itself is not under CPSC jurisdiction, or is a component part not individually mandated for certification by regulation, it may not fall under eFiling requirements. Sellers who are uncertain whether their products are bound by CPSC regulations can conduct a preliminary check through the official CPSC Regulatory Robot, and further verify based on the product's actual use and applicable regulations if necessary.

Is Having a Certificate Enough?

The answer is no. This is currently the biggest misconception among many sellers. Many believe: "I already have a CPC." "I've had a GCC for a long time." "The product has been selling for years without any issues." In reality, eFiling does not introduce a new certificate; it adds an electronic filing step on top of your existing certificates.

In the future, in addition to holding the certificate, you must input the relevant information into the system in advance and complete electronic verification during customs clearance. In other words: having a certificate is the foundation. Completing the electronic filing truly satisfies the new regulatory demands. It requires special clarification that eFiling will not replace original testing, certification, or certificate requirements, but rather adds an electronic filing step to the existing compliance framework.

What Data Needs to be Submitted During Filing?

According to official CPSC requirements, seven primary fields of information are involved:

• 1. Product Identifier
  Unique identification information used to recognize the product, such as SKU, model number, UPC, GTIN, or internal company product code.

• 2. Citation Code
  The consumer product safety regulations, standards, or rules applicable to the product, such as ASTM F963, 16 CFR Part 1303, etc.

• 3. Date of Manufacture
  The manufacturing date or production batch information of the product.

• 4. Manufacturer Information
  The location where the product was manufactured, produced, or assembled, including the manufacturer's name, full address, and contact information.

• 5. Testing Date
  The completion date of the most recent test used to support the product's compliance claim or certificate issuance.

• 6. Testing Laboratory Information
  Information about the laboratory that issued the test results, including laboratory name, address, and contact details; laboratories for children's products must hold CPSC-accepted qualifications.

• 7. Records Custodian
  Contact information for the individual responsible for maintaining test reports, certificates, and related compliance records, including name, full address, and contact details.

Critical Warning: All information must remain strictly consistent with the contents of the test reports and certificates. Inconsistent data, errors, or missing details can negatively impact the system's verification results.

Who is Responsible for Completing the Filing?

This is one of the most frequently asked questions recently. Many sellers think: "The freight forwarder helps me clear customs, so do I need to worry about anything?" In reality, this is not the case. Although data is typically submitted through the ACE system by customs brokers, the ultimate responsibility for the authenticity of product information and the validity of certificates may still be traced back to the importer, brand owner, or manufacturer.

Therefore, sellers cannot entirely rely on logistics service providers to handle it.

Before shipping, it is best to confirm in advance:

• Whether the test report is valid

• Whether the certificate meets requirements

• Whether the filing data is complete

This is the only way to avoid unnecessary risks later on.

Customs Broker / Freight Forwarder

• Main Responsibilities: Completes data entry and message submission through the ACE system.

• Responsibility Positioning: Generally assumes operational responsibility for filing; may be held liable in cases of intentional misconduct or gross negligence.

US Importer (Importer of Record)

• Main Responsibilities: Verifies the authenticity of product information, certificates, and filing data, and completes the import declaration.

• Responsibility Positioning: The primary subject of compliance liability.

Chinese Seller / Brand Owner

• Main Responsibilities: Provides authentic and complete test reports, certificates, and product information.

• Responsibility Positioning: May bear direct or joint liability depending on their actual role and identity.

Testing Laboratory

• Main Responsibilities: Issues test reports and ensures that test results comply with relevant requirements.

• Responsibility Positioning: Bears responsibility for the authenticity of test results and the compliance of their qualifications.

Although eFiling can be submitted by customs brokers or freight forwarders on your behalf, legal liability does not shift simply due to outsourcing to a third party. The US Importer remains the primary liable entity, and relevant sellers, brand owners, and testing institutions may also bear corresponding responsibilities depending on the actual circumstances.

How Much Cost Will eFiling Add?

As things stand, the CPSC does not charge official filing fees for eFiling itself. However, sellers may still incur the following costs:

• Product testing fees

• Laboratory testing fees

• CPC creation fees

• GCC creation fees

• Compliance consulting fees

• Customs brokerage service fees

For sellers who already possess a comprehensive testing framework, the added costs are usually not very high. Truly high costs often arise when a product has not undergone standardized testing previously, certificates are missing, or documentation is incomplete. Therefore, the earlier preparation begins, the lower the overall rectification costs tend to be.

Common Pitfalls for Sellers to Avoid

• Pitfall 1: Using a GCC instead of a CPC for children's products.
  This is one of the most common issues. Children's products must meet corresponding children's product requirements and cannot simply be substituted with a general consumer product certificate.

• Pitfall 2: Continuing to use old certificates after product upgrades.
  If the product structure, material, or safety parameters change, testing and certification requirements should be re-confirmed.

• Pitfall 3: Multiple products sharing the exact same certificate.
  Different product models should generally correspond to their respective testing and certification documentation.

• Pitfall 4: Believing a product is definitely compliant just because it has been sold for many years.
  The eFiling audit is based on regulatory requirements and testing documentation, not sales history.

With Less Than Three Weeks to Official Implementation on July 8, How Should Sellers Prepare for Compliance?

With less than three weeks remaining before the official enforcement on July 8, 2026, the most important thing for US marketplace sellers right now is not to wait and see, but to complete a systematic compliance review as quickly as possible.

Step 1: Organize Active SKUs on the US Site

First, compile a complete list of all products exported to the US, including:

• Amazon US products

• TikTok Shop US products

• Independent website products

• Overseas warehouse inventory products
  It is recommended to set up an SKU ledger to prevent omissions.

Step 2: Confirm if Products Fall Under CPSC Jurisdiction

Many sellers are unsure if their products require eFiling. You can check the corresponding regulatory requirements for your products using the official CPSC tool, the Regulatory Robot. Pay close attention to:

• Toys

• Baby and children's products

• Household goods

• Luminaires

• Small home appliances

• Lithium battery products

• Outdoor products
  If the product itself requires a CPC or GCC certificate, it generally requires a further evaluation of eFiling requirements.

Step 3: Audit Existing Test Reports and Certificates

Focus your check on:

• Whether the certificate is authentic and valid

• Whether the product models match exactly

• Whether the testing standards are the latest versions

• Whether the product has undergone changes in structure, material, or function
  The biggest risk for many sellers is not lacking a certificate, but having a certificate that does not match the actual product.

Step 4: Determine the Filing Method

Choose an appropriate solution based on your shipping volume:

• Low shipment volume: File directly through a customs broker via the ACE system.

• High SKU count / Long-term US market commitment: It is recommended to register a CPSC Product Registry account to establish a product database in advance, which will improve subsequent filing efficiency.

Step 5: Confirm the Filing Process with Service Providers in Advance

It is recommended to connect with your:

• Testing institutions

• Compliance service providers

• Customs brokers

• US importers
  Confirm the following details well ahead of time:

• Who is responsible for filing

• Who provides the certificates

• Who maintains the filing records

• How data will be submitted during customs clearance
  This prevents finding out that documentation is missing after the goods have arrived at the port.

Step 6: Mind the Timeline

Currently, less than three weeks remain before the official July 8 implementation. If a product requires supplemental testing, re-issuance of CPC/GCC certificates, additional test reports, or refinement of filing data, it generally takes 2 to 4 weeks.

As the policy effective date draws closer, the processing volume for testing institutions, laboratories, customs brokers, and service agencies will increase rapidly. Sellers are advised to try and complete self-checks and documentation prep before the end of June to avoid missing shipment schedules due to incomplete materials.

Final Check: Pre-Launch Self-Audit Checklist for eFiling

Please confirm whether the following items have been completed:

• Sorted through all active SKUs on the US site

• Confirmed whether products fall within the CPSC regulatory scope

• Completed product testing

• Obtained valid CPC/GCC certificates

• Confirmed the filing method

• Confirmed the filing process with the customs broker

• Prepared relevant filing documentation

If any of the items above remain uncompleted, it is highly recommended to launch your compliance review immediately.

Closing Thoughts

Over the past few years, compliance requirements in the US market have been steadily rising—moving from trademarks, patents, and copyrights, to platform AI audits, and now to today's eFiling electronic filing. The underlying regulatory logic is shifting clearly.

In the future, sellers who can maintain long-term stable operations in the US market will rely on more than just product selection and operational skills. More importantly, they will rely on an enterprise's compliance management capability. The countdown to the official implementation on July 8 has entered its final stretch.

If your products involve regulated categories such as children's items, household goods, electronics, or battery products, it is highly recommended to complete your review and preparation as early as possible. Resolving risks before shipping is always far more cost-effective than attempting remedies after the goods have reached the port.