CPSC’s New E-Filing Mandate: What Importers Need To Know

For over fifteen years, importers of regulated consumer products operated under a reactive compliance model: certificates of compliance were required at the time of import under the Consumer Product Safety Improvement Act of 2008, but importers only had to produce them on CPSC’s request.

That reactive model ended July 8, 2026. A Final Rule published January 8, 2025, amending 16 C.F.R. Part 1110, made electronic filing of certificate data mandatory at time of entry, through CPSC’s Partner Government Agency (PGA) Message Set within CBP’s Automated Commercial Environment (ACE). See 90 Fed. Reg. 1,800 (Jan. 8, 2025). The requirement extends to goods withdrawn from Foreign Trade Zones for consumption or warehousing beginning January 8, 2027. There is no de minimis exception: eFiling applies at every shipment value, including entries that previously qualified for informal, low-documentation treatment under Section 321. Id.

Importers have three filing options, and different lines within a single consolidated entry may use different methods:

• Disclaimer. Used where a product falls under a CPSC-flagged HTS code but requires no certificate. Disclaim A covers products for which no certificate is required at all; Disclaim B covers products where CPSC exercises enforcement discretion despite an applicable rule.
• Reference Message. Certificate data is filed once with CPSC’s Product Registry in advance; each subsequent entry references the stored certificate.
• Full Message. Complete certificate data is filed with each individual entry.

The underlying certification obligation has not changed, only how and when the data reaches the government. CPSC has published a guidance list of several hundred HTS codes likely to include regulated products. The list is not exhaustive, and inclusion or omission does not determine whether a given product requires certification; that turns on the product itself, not its tariff classification. Importers remain responsible for that determination regardless of whether ACE flags the line.

The requirement applies to finished products imported for consumption, warehousing, or distribution. Component parts destined for further U.S. manufacturing fall outside its scope. Brokers and consolidators may transmit the data, but certification responsibility remains with the importer of record unless the IOR designates the owner, purchaser, or another party with a financial interest in the goods as responsible.

Each entry receives a status through ACE’s PGA messaging: “May Proceed” (cleared), “PGA Under Review” (goods may reach the importer’s premises but cannot enter commerce pending CPSC review), or a deficiency notice requiring correction and retransmission. Noncompliant or incomplete filings feed CPSC’s risk-scoring system, increasing exams and holds on future shipments; consequences for failure can include prolonged port holds, seizure, and civil or criminal exposure under the CPSA.

To prepare, importers should require manufacturers to supply, before goods leave origin: product identification, the applicable safety rule(s), date and place of manufacture, date and place of testing, the testing laboratory, the certifying party, the records custodian, and any testing exclusions relied upon. Certificates and underlying test records must be retained for five years.

This is an administrative layer on an existing obligation, not a new substantive duty. Importers who have certified compliant products all along have little to adjust beyond filing mechanics. Importers who were previously lax about the underlying requirement now face that exposure at the border in real time.

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