# CPSC eFiling market size: CPSC's own estimates

> CPSC estimated that its eFiling rule affects 246,438 small importers (211,148 importing children's products, 35,290 non-children's) and generates about 57.5 million filings a year, 46.5 million of them short Reference message sets. It put the average broker fee at $0.77 per certificate filing and the first-year cost at $1,104 per small importer. These are CPSC's estimates in the final rule (90 FR 1800, January 2025), not observed counts.

Last checked 2026-09-22 · Source: https://www.federalregister.gov/documents/2025/01/08/2024-30826/certificates-of-compliance · CC BY 4.0

| Measure | CPSC estimate | Unit | Where in the rule |
|---|---|---|---|
| Small importers affected by the rule | 246,438 | firms | FRFA Table 2 |
| of which import children's products (CPC) | 211,148 | firms | FRFA Table 2 |
| of which import non-children's products (GCC) | 35,290 | firms | FRFA Table 2 |
| Small businesses affected, importers and manufacturers | 273,061 | firms | FRFA Table 2 |
| Small domestic manufacturers affected | 26,623 | firms | FRFA Table 2 |
| Respondents eFiling Children's Product Certificates | 224,000 | respondents | PRA Table 14 |
| Respondents eFiling General Certificates of Conformity | 40,665 | respondents | PRA Table 13 |
| eFilings per year, all message types | 57,500,000 | filings / year | PRA, footnote 31 |
| Product Registry filings | 2,300,000 | filings / year | PRA, footnote 31 |
| Full PGA Message Sets | 1,700,000 | filings / year | PRA, footnote 31 |
| Reference PGA Message Sets | 46,500,000 | filings / year | PRA, footnote 31 |
| Disclaimer Message Sets | 7,000,000 | filings / year | PRA, footnote 31 |
| CPC eFiling responses | 34,055,116 | responses / year | PRA Table 14 |
| GCC eFiling responses | 23,491,168 | responses / year | PRA Table 13 |
| Certificates created annually by small importers | 214,806 | certificates / year | FRFA Table 3 |
| Active General Certificates of Conformity (June 2024) | 597,202 | certificates | Recordkeeping analysis |
| Average broker fee per certificate filing | $0.77 | USD | FRFA footnote 56 |
| Assumed maximum broker fee per entry (Beta Pilot brokers) | $25 | USD | FRFA footnote 56 |
| Filings each certificate generates a year | 23.7 | filings / certificate / year | FRFA footnote 57 |
| Average first-year cost per small importer | $1,104 | USD | FRFA, Table 10 text |
| for importers of non-children's products | $1,137 | USD | FRFA, Table 10 text |
| for importers of children's products | $1,099 | USD | FRFA, Table 10 text |
| First-year cost to all small importers | $272,180,000 | USD | FRFA, Table 10 text |
| Estimated time per eFiling action (22 seconds) | 0.37 | minutes | PRA |
| Estimated cost to build a Product Registry API integration | $9,750 | USD | Response to comment 53 |
| Estimated annual maintenance of that integration | $2,880 | USD / year | Response to comment 53 |

## Key findings

- **Reference filings dominate.** CPSC expected 81% of filings (46.5M of 57.5M) to be Reference message sets pointing to the Product Registry, so the Registry is central to its design.
- **Children's products are most of it.** 211,148 of the 246,438 small importers (85.7%) import children's products, and CPC filers (224,000 respondents) far outnumber GCC filers (40,665).
- **Cheap per filing, not per importer.** At $0.77 per filing and 23.7 filings per certificate a year, broker fees come to about $16 per certificate a year; the $1,104 first-year average is mostly start-up cost.
- **Nobody counts the real number yet.** CPSC publishes no count of Product Registry accounts or eFiled entries. We will add observed figures when CPSC or CBP publish them.

## Methodology

Figures are copied from the final rule's Final Regulatory Flexibility Analysis (FRFA) and Paperwork Reduction Act (PRA) sections; each row names its table or footnote.'Small importer' follows CPSC's use of SBA size standards. CPSC assumed a small importer files 10% of the certificates an average firm in its industry files.The respondent counts (224,000 CPC, 40,665 GCC) and the small-importer counts come from different parts of the analysis and should not be added together.We have not adjusted anything. Where the rule's own sections differ, both figures are shown with their location.

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