CPSC eFiling market size: how many importers and filings
CPSC's own estimates from the final rule, in one table: importers affected, filings a year by type, broker fees and cost per importer.
Last checked: 2026-09-22 · Source: final rule 90 FR 1800 Federal Register: Certificat · Licence: CC BY 4.0
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. Federal Register: Certificat
All figures
Each row is one number from the final rule, with its location.
| 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 |
57.5 million filings a year, by type
CPSC's estimate of annual filings, all importers.
Key findings
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.
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).
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.
CPSC publishes no count of Product Registry accounts or eFiled entries. We will add observed figures when CPSC or CBP publish them.
Methodology and limitations
- 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.
How to cite this dataset
ComplyGoods, CPSC eFiling market size, version 2026-09-22. https://complygoods.com/data/efiling-market-size/. Licensed CC BY 4.0.
Machine-readable twin for assistants: https://complygoods.com/data/efiling-market-size.md
Founder of ComplyGoods. Publishes open data on product-compliance regimes (also eprfrancerep.com and eprgermanyrep.com). Every figure here links to the government file or provider page it was read from.
Razvan Toma on LinkedIn ↗Importing consumer products into the US?
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