# CPSC eFiling FAQ Checked 2026-09-22 ## Basics **When did CPSC eFiling become mandatory?** On 8 July 2026 for regulated imported consumer products in general. Mail shipments follow on 22 October 2026, and goods entered from a Foreign Trade Zone on 8 January 2027. (Sources: https://www.cpsc.gov/Business--Manufacturing/Business-Education/Business-Guidance/Certificates, https://content.govdelivery.com/accounts/USCPSC/bulletins/427e935, https://www.cpsc.gov/s3fs-public/2025_07_21eFilingFTZGuidance.pdf) **Did eFiling create new testing requirements?** No. CPSC says eFiling creates no new testing, certification or compliance obligations; it changes how certificate data is transmitted. Certificates must now also list any testing exclusions relied on. (Sources: https://www.cpsc.gov/Newsroom/News-Releases/2026/CPSC-Implements-Mandatory-eFiling-for-Certificates-of-Compliance-Targeting-Dangerous-Foreign-Imports, https://www.cpsc.gov/FAQ/eFiling-Frequently-Asked-Questions-FAQ) **Who has to eFile?** The importer: the party eligible to make entry, whether owner, purchaser, consignee or authorised customs broker, whenever the imported finished product requires a CPC or GCC. (Sources: https://www.cpsc.gov/efiling/importers, https://www.federalregister.gov/documents/2025/01/08/2024-30826/certificates-of-compliance) **Does eFiling apply to domestically made products?** No. CPSC's acting chairman said eFiling does not apply to domestic manufacturers. The revised certificate content rules in 16 CFR part 1110 do apply to them from 8 July 2026. (Sources: https://www.cpsc.gov/Newsroom/News-Releases/2026/CPSC-Implements-Mandatory-eFiling-for-Certificates-of-Compliance-Targeting-Dangerous-Foreign-Imports, https://www.cpsc.gov/Business--Manufacturing/Business-Education/Business-Guidance/Certificates) **Is there a de minimis or low-value exemption?** No. The rule has no de minimis exemption, and CBP's Entry Type 13 brings mail shipments into eFiling from 22 October 2026. (Sources: https://www.federalregister.gov/documents/2025/01/08/2024-30826/certificates-of-compliance, https://content.govdelivery.com/accounts/USCPSC/bulletins/427e935) **Do consumer-to-consumer marketplace sales need eFiling?** Yes. CPSC treats sales between consumers through an online marketplace as commercial. Only a noncommercial gift or personal-effects transfer, of goods the sender already held, is outside eFiling. (Sources: https://www.cpsc.gov/FAQ/eFiling-Frequently-Asked-Questions-FAQ) **Do used, resold or overstock products need eFiling?** Resold and overstock regulated products do. Used products need a certificate, and eFiling, only if they were made after the relevant rule took effect. (Sources: https://www.cpsc.gov/FAQ/eFiling-Frequently-Asked-Questions-FAQ) **Do samples need to comply?** Samples imported only to solicit orders or for testing, and never distributed to consumers, need not comply. CPSC points importers to CBP's sample options; test prototypes use HTS 9817.85.01. (Sources: https://www.cpsc.gov/FAQ/eFiling-Frequently-Asked-Questions-FAQ) ## Filing and the Product Registry **What are the seven data elements of a Full PGA Message Set?** Product ID, citation codes, manufacture date, manufacture place, product test date, testing laboratory and point of contact. (Sources: https://www.cpsc.gov/FAQ/eFiling-Frequently-Asked-Questions-FAQ) **What is a Reference PGA Message Set?** A short filing carrying three identifiers (Certifier ID, Product ID and Version ID) that point to a certificate stored in CPSC's Product Registry. (Sources: https://www.cpsc.gov/FAQ/eFiling-Frequently-Asked-Questions-FAQ, https://www.cpsc.gov/s3fs-public/Product_Registry_Frequently_Asked_Questions_V1-4.pdf) **Is the Product Registry free?** Yes. CPSC does not expect to charge for the Product Registry. (Sources: https://www.federalregister.gov/documents/2025/01/08/2024-30826/certificates-of-compliance, https://www.cpsc.gov/eFiling-CPSC-Product-Registry) **Do I have to use the Product Registry?** No. It is only needed for Reference message sets; Full message sets are filed without it. (Sources: https://www.cpsc.gov/FAQ/eFiling-Frequently-Asked-Questions-FAQ) **Does the Product Registry send data to ACE?** No. It is a standalone repository. The importer gives its broker the three certificate identifiers to file in ACE. (Sources: https://www.cpsc.gov/FAQ/eFiling-Frequently-Asked-Questions-FAQ, https://www.cpsc.gov/eFiling-CPSC-Product-Registry) **Can my broker or consultant manage the Product Registry for me?** They can work in it if invited. The importer must create the Business Account and can invite trade-partner users into its Product Collections; certification stays the importer's responsibility. (Sources: https://www.cpsc.gov/s3fs-public/Product_Registry_Frequently_Asked_Questions_V1-4.pdf) **Can I upload certificates in bulk?** Yes, with CPSC's CSV bulk upload template or through the Product Registry API. (Sources: https://www.cpsc.gov/FAQ/eFiling-Frequently-Asked-Questions-FAQ, https://www.cpsc.gov/eFiling-Document-Library) **How long can I edit a certified certificate?** For 48 hours after certification under the same Version ID, unless it has been used in a Reference message set. After that you create a new version. (Sources: https://www.cpsc.gov/s3fs-public/Product_Registry_Frequently_Asked_Questions_V1-4.pdf) ## Certificates and testing **What is the difference between a CPC and a GCC?** A CPC covers children's products (designed primarily for children 12 and under) and needs third-party testing by a CPSC-accepted lab. A GCC covers regulated general-use products. (Sources: https://www.cpsc.gov/FAQ/CPC, https://www.cpsc.gov/Business--Manufacturing/Testing-Certification/General-Certificate-of-Conformity) **Can my Chinese factory issue the certificate?** For imported products the importer is the certifier. The importer may rely on the factory's testing and certification, with due care, when it issues its own certificate. (Sources: https://www.federalregister.gov/documents/2025/01/08/2024-30826/certificates-of-compliance, https://www.cpsc.gov/s3fs-public/Product_Registry_Frequently_Asked_Questions_V1-4.pdf) **Does every SKU need its own certificate?** Every unique product does. A material change to design, manufacturing process or component source makes a new product; apparel of the same material made and tested together is one product. (Sources: https://www.cpsc.gov/s3fs-public/Product_Registry_Frequently_Asked_Questions_V1-4.pdf) **How many CPSC-accepted labs are there?** Our count of CPSC's list on 22 September 2026: 737 laboratories, 341 of them in mainland China, 84 in Shenzhen. See the labs dataset. (Sources: https://www.cpsc.gov/cgi-bin/labsearch/) **Do I need to list component test reports?** Yes, when you rely on them. Certificates must identify each lab and the rules it tested for, whether the test was on the finished product or a component. (Sources: https://www.cpsc.gov/FAQ/eFiling-Frequently-Asked-Questions-FAQ) ## Enforcement **Will CBP reject my entry if CPSC data is missing?** No. ACE accepts it. CPSC can reject the CPSC data, raise the entry's risk score and take enforcement action, including requesting seizure. (Sources: https://content.govdelivery.com/accounts/USDHSCBP/bulletins/422b123, https://www.cpsc.gov/FAQ/eFiling-Frequently-Asked-Questions-FAQ) **How many Notices of Violation has CPSC issued?** CPSC's spreadsheet lists 39,928 violative samples from January 2009 to April 2026; 4,308 were in 2025, the highest year in the file. See the violations dataset. (Sources: https://www.cpsc.gov/Recalls/violations) --- ComplyGoods · https://complygoods.com/faq/ · Independent. Not affiliated with or endorsed by the U.S. Consumer Product Safety Commission (CPSC) or U.S. Customs and Border Protection (CBP).