U.S. CPSC Consumer Products Electronic Filing & Consulting

On December 8, 2023, the U.S. Consumer Product Safety Commission (CPSC) issued a Supplemental Notice of Proposed Rulemaking (SNPR) to amend 16 CFR Part 1110, Uniform Requirements for Certification of Compliance.

Electronic Filing (eFiling) is an initiative promoted by the CPSC, requiring importers of consumer products to electronically submit compliance data via the Automated Commercial Environment (ACE) system of U.S. Customs and Border Protection (CBP). Companies may use the ACE Partner Government Agency (PGA) message set to extract and submit data from Certificates of Compliance.

This initiative aligns with the CPSC’s mission to reduce the risk of unreasonable injury or death from consumer products and protect U.S. consumers. It also aims to strengthen product safety and compliance monitoring through risk assessment.

eFiling will apply to all products currently requiring a General Certificate of Conformity (GCC) or Children’s Product Certificate (CPC). This includes private-label products, national brands, and all apparel subject to 16 CFR Part 1610 (Standard for the Flammability of Clothing Textiles), regardless of exemption status. This rule may significantly expand the scope of products requiring GCC.

Information, documents, and data stored via eFiling are not available to the general public; access is restricted to government agencies and personnel authorized by the user account.

Consumer Products Subject to Mandatory eFiling

Consumer products requiring a GCC or CPC must comply with eFiling requirements, including:

• Private-label products

• National brands

Key Provisions of eFiling

The U.S. Consumer Product Safety Commission (CPSC):

• Designates the responsible entity that must issue certificates for finished products, as specified in Section 14(a) of the Consumer Product Safety Act (CPSA), as amended (15 U.S.C. 2063(a)).

• Establishes certificate content, format, and availability requirements under Section 14 of the CPSA.

• Mandates electronic filing via CBP for imported finished products requiring certification.

• Clarifies provisions applicable to component part certificates.

For finished products manufactured outside the U.S. and imported via shipment, the certifier must enter GCC or CPC data (per § 1110.11) into the CPSC Product Registration System before the product arrives at a U.S. port.

Proposed Rules on Certificate Availability:

• Furnishing of certificate (§ 1110.13(b)): The certifier must provide the required GCC or CPC to distributors or retailers of the finished product.

• Certificate availability (§ 1110.13(c)): The certifier must provide the certificate for inspection within 24 hours upon request by CPSC or CBP.

To satisfy § 1110.13(b) and (c), electronic certificates must:

• Be clearly identified with a unique identifier on the finished product, shipping package, or invoice.

• Be accessible to CPSC, CBP, distributors, and retailers via URL or other electronic means on the date the product is distributed in commerce.

If protected by a password, the password must be provided immediately upon request by CPSC or CBP.

Compliance Deadlines

• CPSC mandatory eFiling: July 8, 2026

• Import compliance for foreign free trade zones: January 8, 2027

With only months remaining before these deadlines, the U.S. import access rules for consumer products are undergoing fundamental changes.

How JJR LAB Supports Your CPSC eFiling Compliance

With deep expertise in global consumer product regulations and a worldwide network of experts and laboratories, JJR LAB helps you meet CPSC eFiling requirements. Our services include:

• Product Assessment: Evaluate whether your product is subject to CPSC rules, bans, or standards requiring eFiling.

• Product Testing & Certification: Support compliance demonstration and issue CPC / GCC as needed.

• eFiling Support: Prepare and submit product compliance information required by CPSC.

• Technical Guidance: Assist with new eFiling requirements from CPSC and U.S. Customs and Border Protection (CBP).