What it is
Terms to know
- CPSC: The U.S. Consumer Product Safety Commission, the agency that sets and enforces safety standards for consumer products sold in the United States.
- Children's Product Certificate (CPC): A certificate required for children's products subject to CPSC safety standards, such as toys, children's apparel, and juvenile furniture.
- General Certificate of Conformity (GCC): A certificate required for general-use consumer products subject to a CPSC safety rule or ban.
- ACE (Automated Commercial Environment): CBP's system for processing import and export data.
- PGA Message Set: An electronic data transmission sent through ACE on behalf of a Partner Government Agency — in this case, CPSC.
- Product Registry: CPSC's online repository for storing certificate data and generating reference identifiers for use in ACE filings.
Importers of regulated consumer products have been required to hold a certificate of conformity since 2008. Previously, that certificate only needed to be produced if CBP or CPSC requested it — typically after a shipment was flagged for inspection.
eFiling changes the process from reactive to proactive. Instead of waiting to be asked, importers must now transmit certificate data to U.S. Customs and Border Protection (CBP) at the time of entry—or pre-register the data ahead of time—through ACE via a CPSC PGA Message Set.
What's actually changing is significant: before July 8, you held your certificate and only had to provide it if asked. Now you must proactively submit that certificate data on every applicable shipment, before CBP releases your goods. That's a meaningful shift in day-to-day operations — and missing it may result in shipment delays.
Who it affects
eFiling applies to importers of finished consumer products subject to CPSC mandatory safety standards, rules, or bans. This includes:
- Children's products that require a Children's Product Certificate (CPC) — such as:
- Toys and games
- Children's clothing and sleepwear
- Juvenile furniture (cribs, bassinets, toddler beds, bunk beds)
- Strollers, carriers, and car seats
- Nursery equipment (high chairs, play yards, bouncers)
- Bicycle helmets
- Pacifiers and rattles
- General-use consumer products that require a General Certificate of Conformity (GCC) — such as:
- Mattresses and bedding
- Lighters, candles, and fireworks
- Bicycles and ATVs
- Power equipment (lawnmowers, portable generators)
- Seasonal and decorative lighting
- Electrical products (extension cords, hair dryers, appliances)
- Garage door operators
- Rugs, carpets, and floor coverings
This is not an exhaustive list. Visit CPSC's regulations, mandatory standards, and bans to view all affected products.
eFiling does not apply to:
- Used products manufactured before the specific CPSC safety rule that applies to them took effect (note: this refers to the underlying safety rule — which has been in place since at least 2008 — not the July 8 eFiling deadline)
- Non-commercial consumer-to-consumer shipments (if money changes hands, eFiling is still required)
- Domestically manufactured products
Note: There is no de minimis exemption (because the U.S. de minimis is gone). Any product that requires certification must have an eFiled certificate regardless of shipment value.
Not sure if your products require a certificate?
Use CPSC's Regulatory Robot to check compliance requirements by product type. Zonos Agency Check also screens products against CPSC and other PGA requirements or ahead of time of import — so you can identify which shipments need a certificate before they reach the border.
Key dates
| Scenario↕ | Mandatory date↕ |
|---|---|
| Most imported regulated consumer products | July 8, 2026 |
| Products entering a Foreign Trade Zone (FTZ), then entered for consumption or warehousing | January 8, 2027 |
Required data elements
When filing, you must provide seven data elements from your CPC or GCC. This data is already on your existing certificates — eFiling is about transmitting it to CBP up front, not creating new documentation.
| No.↕ | Element↕ | Description↕ |
|---|---|---|
| 1 | Product ID | Identification of the finished product (GTIN, UPC, SKU, model, etc.) |
| 2 | Citation codes | The CPSC safety rule(s) or standard(s) the product was certified to |
| 3 | Manufacture date | When the finished product was manufactured |
| 4 | Manufacture place | Name, full address, and contact of the manufacturing party |
| 5 | Product test date | Date of the most recent compliance test |
| 6 | Testing laboratory | Name, address, and contact of the accredited testing lab |
| 7 | Point of contact | The party who maintains the test records (usually the importer) |
How to file
There are two ways to transmit certificate data to CBP.
Reference PGA Message Set
With this method, you enter each product's certificate data once in CPSC's Product Registry. The registry then assigns three Certificate Identifiers: (1) a Certifier ID, (2) a Product ID, and (3) a Version ID. You give those identifiers to your customs broker, and at the time of entry, your broker transmits just those three identifiers in the ACE Message Set instead of the full certificate data. On every future shipment of the same product, your broker references the same identifiers.
Data can be entered in the Product Registry manually, by CSV bulk upload, or via API. You can also grant access to brokers, labs, or other trade partners to act on your behalf.
Note: The Version ID updates whenever you retest or make a material change to the product. Make sure your broker always has your most current Certificate Identifiers.
Full PGA Message Set
With this method, you provide all seven certificate data elements to your broker, who includes them directly in the ACE Message Set with every shipment entry. Each time you import a regulated product, the full certificate data is submitted fresh. This works well if you import a limited number of products or your product catalog changes frequently.
Which method should I use? If you regularly ship the same products, the Reference method saves significant time — you enter the data once per product and reference it on every future shipment. If your catalog changes frequently or you only import a small number of regulated items, the Full Message Set may be simpler.
What happens if you don't comply
CBP may hold or delay shipments missing the required eFiling data. CBP also uses compliance history from ACE filings in its risk-based targeting — a track record of accurate, complete filings can mean fewer examinations and faster releases over time.
Does eFiling change which products need a certificate?
No. Certification has been required since 2008. eFiling only changes how certificate data is filed — it must now be transmitted to CBP electronically at the time of entry.
Do I have to file for every shipment?
Yes, for every entry of a regulated product. If you use the Product Registry (Reference method), you won't need to re-enter your certificate data each time — you'll just reference the identifiers you've already stored.
Can my customs broker file on my behalf?
Yes. Importers are ultimately responsible for certification, but brokers and other trade partners can file on your behalf if you grant them permission in the Product Registry.
Does eFiling apply to low-value shipments?
There is no de minimis exemption (because the U.S. de minimis is gone). Any product that requires a certificate must be eFiled regardless of shipment value.
How Zonos can help
Zonos Agency Check screens products against CPSC and other PGA requirements at the time of import. If you have questions about how CPSC eFiling affects your cross-border shipments, contact us.
If you have questions about this eFiling requirement, reach out to eFilingSupport@cpsc.gov for additional support and guidance.
CPSC eFiling
Learn about the CPSC electronic filing requirement for imported consumer products.
Consumer product safety is about keeping unsafe goods out of people's homes, and July 8, 2026 marks a significant shift in how the U.S. enforces it at the border. Up until July 8th, CPSC compliance certificate data was only required to be provided if asked. Starting July 8th, CPSC eFiling requirements mean that for the first time, importers of regulated consumer products must electronically submit certificate data to U.S. Customs for all applicable products ahead of time of import — not just if they're asked. If you sell children's products, toys, electronics, housewares, or other consumer goods into the U.S., this guide explains what's changing, who it affects, and what you need to do.