CPSC eFiling: Who Files the Certificate of Compliance, and What It Does Not Prove

CPSC eFiling is the electronic transmission of certificate-of-compliance data to US Customs and Border Protection (CBP) at the time an import entry is filed. It became mandatory on July 8, 2026 for most CPSC-regulated consumer products imported for consumption or warehousing. Products entered from a foreign trade zone get until January 8, 2027. The most common misunderstanding is that eFiling is a new certificate, a new approval, or a new test. It is none of those. CPSC describes the rule as a change in how existing certificate data reaches the agency, and the Commission's acting chairman stated at launch that it creates no new testing, certification, or compliance obligations.

What actually changes is narrower and more operational: who transmits the data, when it has to be transmitted, and what happens when the data is incomplete or does not match the shipment. For a marketplace seller, the useful question is not "am I eFiling?" It is: for this shipment, who is the importer of record, what product does the certificate describe, and does that certificate match the SKU in the box? Get those three wrong and the filing becomes a clean transmission of a dirty record.

What CPSC eFiling is, in one paragraph

Under 16 CFR part 1110, a finished consumer product that is subject to a CPSC consumer product safety rule, ban, standard, or regulation must be accompanied by a finished product certificate when it is imported for consumption or warehousing or distributed in commerce. For imports, the certifier is the importer of record. The revised part 1110 adds the electronic filing step: for products manufactured outside the United States and offered for importation, the certifier must eFile the certificate data elements in CBP's Automated Commercial Environment (ACE) at the time of filing the entry, or the entry and entry summary if both are filed together. The rule was published as 90 FR 1800 on January 8, 2025, with the July 8, 2026 effective date.

Two categories of certificate sit under that umbrella. A Children's Product Certificate (CPC) covers a children's product and must be based on testing by a third-party laboratory whose accreditation CPSC has accepted. A General Certificate of Conformity (GCC) covers a non-children's product subject to a CPSC rule and must be based on a test of each product or a reasonable testing program. eFiling applies to both, because both are finished product certificates. The article on what "CPSC certified" really means for baby products covers the CPC side in more detail; this one is about the import filing and its limits.

Who files, and who is the certifier

The rule defines the importer as the Importer of Record (IOR) eligible to make entry under the Tariff Act, which may be an owner, a purchaser, or an authorized customs broker. For an imported finished product, that IOR is the finished product certifier. If the IOR is a broker, the broker may identify the owner, purchaser, or consignee who authorized the entry as the party responsible for the certificate requirements, as part of the certificate data filed in CPSC's message set. That sentence is where most direct-to-consumer sellers need to slow down, because the entity that files the entry is not always the entity that knows the product.

Domestically manufactured products are different. The manufacturer certifies, and a private labeler certifies when the product is privately labeled, unless the manufacturer issues the certificate. The eFiling requirement is for imported finished products; domestic distribution still requires that the certificate accompany the product or shipment and be available for inspection within 24 hours of a CPSC or CBP request.

A few edge cases matter in practice. CPSC says it will not typically treat a consumer buying or receiving a product for personal use as the importer responsible for certification. A noncommercial gift from one consumer to another is generally outside eFiling if the sender had physical possession before shipping, but a sale through an online marketplace is a commercial transaction and is not covered by that exemption. Sample-only imports that will never be distributed or used by consumers are treated differently, but the importer has to be able to show that disposition. Used products manufactured before the applicable rule took effect do not need a certificate; used products manufactured after it do, including when they are imported commercially.

What the certificate has to contain

eFiling does not create a shorter certificate. The data elements are the same content requirements that a paper or electronic certificate carries, which is why an incomplete certificate becomes an operational problem at the port instead of a document request later. CPSC's FAQ lists the seven required elements transmitted with a Full PGA Message Set as product ID, citation codes, manufacture date, manufacture place, product test date, testing laboratory, and point of contact. The regulation adds the certifier's identity and attestation, and requires separate identification of each applicable rule.

Two details are easy to miss. First, a certificate must describe only one product. A family of sizes or colors is not automatically one product for this purpose, and the rule allows additional identifiers to help match a certificate to a specific item. Second, if a statutory or regulatory testing exclusion is claimed, the certificate has to identify the exclusion in place of the test date and place for that rule. CPSC's FAQ also notes that test URL, test report key, and test report ID are optional but encouraged fields, and that supporting records can still be requested.

The two filing routes and the identifier handoff

An importer has two ways to get the data into ACE. With a Full PGA Message Set, the importer gives the broker the required data elements and the broker files them. With a Reference PGA Message Set, the importer pre-enters the certificate in CPSC's Product Registry and gives the broker three certificate identifiers: the certifier ID, the product ID, and the version ID. The Product Registry is a stand-alone repository; it does not communicate with ACE. The broker still has to file the reference in ACE, which is why "we entered it in the registry" is not the same as "the entry was filed."

The timing rules follow the shipment type. For an entry, the data is filed at the time of entry, or at the time of the entry and entry summary if both are filed together. For products imported by mail, the certifier enters the data in the Product Registry before the product arrives in the United States. For foreign trade zones, the requirements apply to merchandise withdrawn for consumption or warehousing and take effect January 8, 2027. And there is no low-value carve-out: CPSC states plainly that a product requiring certification must have an eFiled certificate regardless of shipment value, and that Section 321 (de minimis) shipments are not exempt. The final rule expects those shipments to use an entry type capable of carrying CPSC's message set, which is currently Entry Type 86.

What a filed certificate does not settle

This is the part that matters most for a seller who also publishes listings, videos, and ads. A filed certificate is evidence about a product's compliance with the safety rules it cites. It is not a general permission to sell, and it does not validate the sentences used to sell the product.

1. It does not make CPSC an approver. CPSC does not certify products or approve listing copy. The certificate is issued and signed by the certifying firm. A filed certificate proves the data reached CBP, not that an agency endorsed the item.
2. It does not cover marketing claims. A CPC citing a flammability standard does not substantiate "flame resistant" as a marketing adjective, a safety promise, or a comparative claim. Those are separate questions under the FTC Act, and in some categories under other statutes. The children's sleepwear labeling rules are a useful example of how far apart the certificate and the claim can be.
3. It does not replace the underlying records. Certifiers must keep the certificate and supporting test records for at least five years from the certificate creation date, and make them available to CPSC or CBP within 24 hours of a request. A filing is a summary, not the evidence file.
4. It does not cover products you did not describe. One certificate describes one product. A new material, a new factory, a new bundle, or a new model can all require a new or updated certificate and a new filing.
5. It does not guarantee release. CPSC says that, at this time, it does not intend to ask CBP to deny entry solely because certificate data is missing, and does not intend initially to have ACE send reject messages for missing PGA data, only warning messages. That is an enforcement posture, not a safe harbor. CPSC also says it will continue to enforce certificate requirements and can ask CBP to initiate seizure of non-compliant products. Certificate data can also change an entry line's risk score, which is the point of the program.
6. It does not cover other agencies or states. FDA, EPA, FTC, and state requirements such as California's Proposition 65 operate on their own tracks. A CPSC certificate does not resolve a pesticide claim, an organic claim, or a state warning obligation.

A pre-shipment review pass

Run this before the entry is filed, not after a hold appears.

1. Identify the IOR for the actual routing. Name the entity, not the service. DDP, forwarder, broker, and fulfillment arrangements can all change who is eligible to make entry.
2. Confirm the product is subject to a CPSC rule. Use CPSC's Regulated Product Database and Regulatory Robot as starting points, then confirm the citations for your construction, materials, and age grading with the lab or counsel.
3. Decide CPC or GCC and list every citation. A children's product needs the third-party lab basis; a non-children's product subject to a rule needs the GCC basis.
4. Match the certificate to the SKU on the carton and invoice. The product ID on the certificate should be findable on packaging, the packing list, or the invoice so a port officer can match it.
5. Check the lab's acceptance scope for each citation. A lab accepted for one children's product rule is not automatically accepted for every rule cited on the certificate.
6. Verify all seven data elements and the records contact. Include the attestation and, where claimed, the testing exclusion code.
7. Choose Full or Reference and close the handoff. Give the broker either the complete data set or the three certificate identifiers, and confirm the entry was filed with them.
8. Keep the file for five years. Certificate, test reports, component-part records relied on, and the correspondence that shows the certificate matches the shipped product.
9. Review the listing and video separately. Treat claims as a content review with its own evidence standard, not as an extension of the customs filing.

For the content side, the TikTok Shop claim checker flags absolute and authority wording and names the rule behind each finding; ecommerce listing checks cover catalog copy. Neither replaces the certificate review, and the certificate review does not replace them.

Three hypothetical examples

These are invented scenarios for illustration, not real sellers, and they are not legal advice or a compliance guarantee.

Example A: a children's pajama set shipped direct to a US warehouse. The brand is the IOR. Its supplier sends a CPC that cites the flammability rule but lists a testing lab accepted for a different children's product rule, and the product ID is the supplier's internal code, which appears nowhere on the carton. eFiling transmits the record as written. The useful fix happens before entry: correct the citation-to-lab mapping, add an identifier that matches the shipment, and only then file. The certificate still does not establish that the word "flame resistant" is supported on the listing.

Example B: a brand using a forwarder under DDP terms. The forwarder makes entry and files the data. The brand assumed the supplier handled "compliance" and has never seen the certificate. If CPSC later asks about the shipment, the rule's legal responsibility still sits with the finished product certifier identified under the rule, and the owner, purchaser, or consignee can be treated as responsible. The practical step is to get the IOR's name, the certificate, and the filed data elements before the first shipment, not after a hold.

Example C: a reseller importing overstock children's toys. The goods are commercial, so the consumer-to-consumer gift exemption does not apply. The certificate supplied by the original seller covers a different production run and a different model number. The reseller is the importer for this entry and needs a certificate that describes the goods actually being imported, with the identifiers that match the cartons. "The product was certified before" is not the same as "this shipment is covered by this certificate."

Frequently asked questions

Does eFiling apply to shipments under $800?

CPSC states that any product requiring certification must have an eFiled certificate regardless of shipment value, and that there is no Section 321 (de minimis) exemption for eFiling. The final rule expects de minimis shipments to use an entry type capable of carrying CPSC's message set.

I sell on TikTok Shop or Amazon and never touch customs. Do I still have to file?

The obligation follows the entry, not the sales channel. The IOR is the certifier for the import, and the rule allows a broker that is the IOR to identify the responsible owner, purchaser, or consignee. If you do not know who made entry for your shipment, that is the first thing to establish with your logistics provider. CPSC says it will not typically treat a consumer buying for personal use as the importer, but a marketplace sale is a commercial transaction.

Does eFiling replace the CPC or GCC?

No. It transmits the same certificate data elements. A missing citation, an old test date, or a product identifier that does not match the shipment remains a certificate problem after the filing.

Can I say "CPSC certified" once the data is filed?

No. CPSC does not certify products. You can describe the product as tested to specific rules at a CPSC-accepted lab and state that a certificate is on file, and only if both statements are true for the item being sold. A filing with CBP does not turn that into an agency endorsement.

Does eFiling apply to products made in the United States?

The eFiling requirement applies to imported finished products that are required to be certified. Domestic manufacturers still issue certificates and must make them available within 24 hours of a request, and private labelers may be the certifier.

Do gifts sent between consumers need eFiling?

A noncommercial transaction, such as a gift or transfer of personal effects, is generally outside eFiling when the consumer outside the United States had physical possession before sending the product. Sales through an online marketplace, including consumer-to-consumer sales, are commercial and are not covered by that exemption.

Sources

• US Consumer Product Safety Commission, eFiling - CPSC's Modern Approach for Filing Certificate Data. Reviewed November 14, 2026.
• US Consumer Product Safety Commission, eFiling Frequently Asked Questions, including the seven data elements, Section 321 treatment, Product Registry handoff, and the current statement on missing-data messages. Reviewed November 14, 2026.
• US Consumer Product Safety Commission, CPSC Implements Mandatory eFiling for Certificates of Compliance, July 8, 2026, including the statement that eFiling creates no new testing, certification, or compliance obligations and the January 8, 2027 date for foreign trade zones. Reviewed November 14, 2026.
• Federal Register, Certificates of Compliance, 90 FR 1800, published January 8, 2025, effective July 8, 2026. Reviewed November 14, 2026.
• Electronic Code of Federal Regulations, 16 CFR part 1110, Certificates of Compliance, including sections 1110.7, 1110.9, 1110.11, 1110.13, and 1110.17. Reviewed November 14, 2026.