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 (3)CPSCCPSC: Update on Certificates of Compliance and eFilingCPSC bulletin: eFiling guidaCPSC bulletin: eFiling guidance for mail shipments (1 Sep 2026)CPSCCPSC: eFiling Guidance for Foreign Trade Zones (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 (2)CPSC news release 26-604CPSC news release 26-604 (8 Jul 2026)CPSCCPSC: eFiling 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 (2)CPSCCPSC: eFiling resources for importersFederal Register: CertificatFederal Register: Certificates of Compliance, 90 FR 1800 (8 Jan 2025)
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 (2)CPSC news release 26-604CPSC news release 26-604 (8 Jul 2026)CPSCCPSC: Update on Certificates of Compliance and eFiling
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 (2)Federal Register: CertificatFederal Register: Certificates of Compliance, 90 FR 1800 (8 Jan 2025)CPSC bulletin: eFiling guidaCPSC bulletin: eFiling guidance for mail shipments (1 Sep 2026)
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. CPSC
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. CPSC
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. CPSC
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. CPSC
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 (2)CPSCCPSC: eFiling FAQCPSCCPSC: Product Registry FAQ V1.4 (PDF)
Is the Product Registry free?
Yes. CPSC does not expect to charge for the Product Registry. Sources (2)Federal Register: CertificatFederal Register: Certificates of Compliance, 90 FR 1800 (8 Jan 2025)CPSCCPSC: 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. CPSC
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 (2)CPSCCPSC: eFiling FAQCPSCCPSC: 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. CPSC
Can I upload certificates in bulk?
Yes, with CPSC's CSV bulk upload template or through the Product Registry API. Sources (2)CPSCCPSC: eFiling FAQCPSCCPSC: 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. CPSC
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 (2)CPSCCPSC: Children's Product Certificate FAQCPSCCPSC: 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 (2)Federal Register: CertificatFederal Register: Certificates of Compliance, 90 FR 1800 (8 Jan 2025)CPSCCPSC: Product Registry FAQ 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. CPSC
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. CPSC
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. CPSC
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 (2)CBP CSMS #69382435CBP CSMS #69382435 (29 Jul 2026)CPSCCPSC: eFiling 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. CPSC