Checked against sources: 22 September 2026
No, not at the ACE level. CBP confirmed on 29 July 2026 (CSMS #69382435) that ACE accepts entries with no CPSC message set, or with incomplete CPSC data, as long as the general PGA message set format is followed. That is not a free pass: CPSC can answer with an SO message that rejects the CPSC data, adjusts the entry line's risk score from the certificate data it receives, and may take enforcement action, including requesting seizure of non-compliant products. Sources (4)CBP CSMS #69382435CBP CSMS #69382435 (29 Jul 2026)CPSCCPSC: eFiling FAQFederal Register: CertificatFederal Register: Certificates of Compliance, 90 FR 1800 (8 Jan 2025)CPSCCPSC: Notices of Violation (Excel, updated 20 Aug 2026)
What CBP said
CSMS #69382435 of 29 July 2026: while eFiling is mandatory, ACE "can accept entries that do not have a CPSC message set or entries where the CPSC message set is missing some CPSC data." Software developers were told to let users submit CPSC data "even if the CPSC flagging requirements are not met." CBP will not generate an SX reject, but "CPSC may respond to trade in an SO message, with a review about the CPSC data submitted on the entry, including rejecting the CPSC data." And: "CPSC may perform enforcement actions on any entry that does not have eFiling data attached when required."
What CPSC said
CPSC's eFiling FAQ: it does not intend to ask CBP to deny entry solely for failure to eFile, and does not intend initially to have ACE send reject messages for missing data, only warnings. But CPSC "will continue to enforce certificate requirements for imported consumer products and submit requests to CBP to initiate seizure of non-compliant products", and it "intends to adjust an entry line's risk score based on certificate data provided".
What that means in practice
| Situation | What happens |
|---|---|
| Complete, accurate certificate data filed | Entry proceeds; CPSC says good data should reduce holds and examinations |
| CPSC data missing or incomplete | ACE accepts the entry; CPSC may reject the CPSC data, raise the risk score, examine |
| Product fails a rule, or no valid certificate exists | The underlying violation: CPSC can issue a Notice of Violation and request seizure, as before |
The certificate obligation itself never went away. CPSC's Notices of Violation show what enforcement looks like: in 2026 so far the most frequent violation is "Third Party Certificate Violation". See the violations dataset.
Beware of claims that ACE "holds the shipment"
Some providers tell importers a missing element will hold the shipment at port. CBP's own guidance says ACE accepts the entry. The risk is real, but it runs through CPSC review, risk scoring and examinations, not an automatic ACE reject. CBP can change the configuration, so check the latest CSMS messages.
Sources
Primary sources first; provider pages only for their own prices.
- CBP CSMS #69382435 (29 Jul 2026) — read 2026-09-22
- CPSC: eFiling FAQ — read 2026-09-22
- Federal Register: Certificates of Compliance, 90 FR 1800 (8 Jan 2025) — read 2026-09-22
- CPSC: Notices of Violation (Excel, updated 20 Aug 2026) — read 2026-09-22
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.
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