If you import consumer products into the United States, a filing requirement that spent nearly a decade in pilot testing became mandatory this year. Since July 8, 2026, importers of CPSC-regulated consumer products must submit certificate of compliance data electronically to U.S. Customs and Border Protection at the time of entry.
The rule catches a lot of ecommerce sellers off guard, because it does not behave like most trade regulations. It applies regardless of shipment size or value — including low-value parcels and direct-to-consumer shipments that previously moved with minimal documentation. There is no volume threshold to hide behind.
The good news is that CPSC eFiling imposes no new testing or certification obligations. If you were already required to hold a certificate, you still hold the same certificate. What changed is how that information reaches the government: electronically, at entry, instead of being produced on request. Here is what sellers need in place.
Who this applies to
The requirement falls on the Importer of Record. Manufacturers, suppliers and testing laboratories generate the underlying data, but the IOR is accountable for filing it. If you, your exporter or a marketplace acts as IOR, that party carries full responsibility.
Two certificate types are in scope:
- A General Certificate of Conformity (GCC) for general-use consumer products subject to a CPSC rule, ban, standard or regulation.
- A Children’s Product Certificate (CPC) for products designed primarily for children 12 and under, which additionally require testing at a CPSC-accepted third-party laboratory.
Notable carve-outs: the rule does not apply to domestic manufacturers producing in the United States, to noncommercial gifts sent consumer to consumer, or to components used in further U.S. manufacturing. Products entered through Foreign Trade Zones have a later compliance date of January 8, 2027.
The seven data elements
An electronic certificate carries the same substance as the paper version it replaces:
| # | Data element | Where it usually comes from |
|---|---|---|
| 1 | Product identifier (GTIN, SKU, UPC, model, serial or alternate ID) | Your own catalog |
| 2 | Each CPSC safety rule the finished product is certified to | Supplier or compliance consultant |
| 3 | Date of manufacture | Factory production record |
| 4 | Place of manufacture with manufacturer name, address and contact | Supplier |
| 5 | Date of most recent compliance testing | Test report |
| 6 | Testing laboratory name, address and contact | Test report |
| 7 | Name, address and contact of the party keeping test records | Usually the importer |
Element 2 is where most sellers stall. Mapping a SKU to every applicable CPSC rule is a genuine compliance exercise, not a data-entry task, and suppliers frequently supply incomplete answers. Start there.
Two ways to file
Both methods run through CBP’s Automated Commercial Environment (ACE):
| Full PGA Message Set | Reference PGA Message Set | |
|---|---|---|
| Cómo funciona | All seven elements transmitted with every shipment at entry | Certificate pre-loaded into the CPSC Product Registry; entry cites Certifier ID, Product ID and Version ID |
| Lo mejor para | Few regulated SKUs, one-off or non-repeating shipments | Repeat imports of the same products |
| Effort per shipment | Más alto | Low after initial setup |
| Esfuerzo de configuración | Mínimo | Higher — registry upload required first |
For most ecommerce sellers shipping the same catalog repeatedly, the Reference method is the right answer. You load each product’s certificate once and cite three short identifiers on every subsequent entry. You can use different methods for different product lines, but stay consistent within a line.
Carriers have built this into their brokerage workflows. UPS, for example, accepts the data through its Customs Detail API, through UPS.com and through WorldShip in batch, and applies the same PGA fee it charges for other agencies that require entry-time data. Expect a per-entry charge from whichever broker you use.
What happens at the border
CPSC’s initial enforcement focus covers roughly 600 HTS codes, though products outside that list may still require certification. Flagged shipments receive one of several CBP messages:
- May Proceed — cleared CPSC review, though other agencies may still hold it.
- 1USG Clearance — all relevant agencies have cleared the shipment.
- Under Review — the goods may move to your premises but cannot enter commerce.
- Hold Intact — held for examination until released.
« Under Review » is the status that damages ecommerce operations most quietly. Inventory physically arrives at your warehouse or 3PL, looks available, and must not be sold. If your inventory system does not model that state, you will oversell it.
What to do now
- Map your catalog. Identify every SKU subject to a CPSC rule and the specific rules each one is certified to.
- Collect certificates from suppliers with all seven data elements complete. Partial certificates are the most common blocker.
- Confirm who the Importer of Record is on every lane. Sellers using DDP arrangements are often surprised to learn the answer.
- Choose your filing method and, if using the registry, upload before your next inbound shipment lands.
- Brief your customs broker and confirm the per-entry fee so it reaches your landed cost model.
- Add an « arrived, not sellable » state to your inventory system for goods under review.
- Verify third-party lab acceptance for children’s products — the lab must be CPSC-accepted.
How this fits your landed cost
CPSC eFiling adds a per-entry brokerage fee and, for some sellers, a one-time compliance project to assemble certificate data. Neither is large on its own. The expensive outcome is a hold during peak season, when a week of unavailable inventory costs far more than the filing ever would.
Sellers already consolidating inbound shipments have an advantage here: fewer entries means fewer PGA fees and fewer opportunities for a flag. If you are reviewing your inbound strategy, our guides to costo de desembarque y honorarios de corretaje aduanero cover the arithmetic.
Fee and threshold figures cited here are indicative and vary by broker, carrier agreement and service. Confirm current requirements with your broker and with CPSC before relying on them, and treat this guide as operational background rather than legal advice.
Get ahead of the holds
CPSC eFiling is not a tax or a tariff — it is a documentation discipline. Sellers with clean supplier data and a registry entry per SKU barely notice it. Sellers chasing certificates after a container is already flagged lose weeks.
Not sure which of your SKUs are in scope, or whether your broker is set up for the Reference message set? Aquí estamos helps online sellers map catalogs to import requirements, structure inbound shipments to minimize entries, and keep cross-border inventory moving through peak. Talk to us before your next purchase order ships.
