CPSC eFiling: Product Certificates for US Importers and Sellers
If you import consumer products into the US, product safety paperwork is no longer something you keep in a drawer until someone asks. Since July 8, 2026, the certificate that shows your product meets US safety rules must be filed electronically with customs for most regulated imports. This guide explains which certificate you need, what data goes into the filing, and how factories and brands can get ready.
The rule in brief
On January 8, 2025, the US Consumer Product Safety Commission (CPSC) published its final rule on Certificates of Compliance in the Federal Register (90 FR 1800). Made in consultation with US Customs and Border Protection (CBP), it updates CPSC's certificate rule (16 CFR Part 1110) and requires electronic filing ("eFiling") of certificate data with CBP when regulated products are imported.
| Item | What the rule says | Source |
|---|---|---|
| Published | January 8, 2025 (90 FR 1800) | Federal Register |
| Effective for most imports | July 8, 2026 | Federal Register |
| Goods entered from a foreign trade zone (FTZ) | January 8, 2027 | Federal Register |
| Low-value (de minimis) shipments | Not exempt; certified products need an eFiled certificate regardless of value | GDLSK (May 19, 2026) |
| Record keeping | Keep certificates and supporting records for at least 5 years | GDLSK (May 19, 2026) |
Which certificate do you need?
Not every product needs a certificate; it depends on whether CPSC rules, bans or standards apply to it. If they do, there are two types:
- Children's Product Certificate (CPC) for products designed or intended mainly for children 12 and under. Certification must be based on testing by a CPSC-accepted third-party lab.
- General Certificate of Conformity (GCC) for general-use products covered by a CPSC rule (for example, certain mattresses, bicycle helmets or products with specific flammability rules). Certification must be based on a test of each product or a reasonable testing program; third-party testing is not required.
If you are unsure whether your product is regulated, start with CPSC's eFiling resources, including the "Does eFiling apply to me?" page, or ask a testing lab or customs broker.
What goes into the filing
According to law firm GDLSK (May 19, 2026), the certificate data filed with CBP includes:
- Product identification, with at least one unique identifier (such as GTIN, model number, SKU or UPC) and a description that matches the product to the certificate
- Each CPSC rule the product is certified to
- Contact details of the certifier and the person who keeps the test records
- Date and place of manufacture
- Date and place of testing
- An attestation that the product complies
There are two ways to file through CBP's ACE system. With the full message set, all certificate data is sent with each entry. With the reference message set, the importer stores certificates in CPSC's Product Registry and sends only a reference ID with each entry, which is easier for products imported repeatedly.
Who does what
The importer of record is responsible for the certificate and the filing; in practice the customs broker usually transmits the data. That means factories that ship on DDP terms or act as importer for their own US sales carry this responsibility themselves. Brands that buy from factories need the factory's test reports and production data early enough to give the broker before the goods arrive.
Missing or wrong certificate data can lead to delays in releasing your shipment and more inspections at the port, GDLSK notes. For marketplace sellers, a container held in port during Q4 can mean stock-outs at the worst time.
Step-by-step readiness checklist
- List your SKUs and mark which are children's products, which are general-use products covered by a CPSC rule, and which are not regulated.
- Collect test reports from a CPSC-accepted lab for children's products, and test or testing-program records for general-use products.
- Create one certificate per product (CPC or GCC) with all required data, including manufacture date and place.
- Decide how to file: full message set or reference IDs through the CPSC Product Registry.
- Brief your customs broker and send certificate data before each shipment leaves.
- Update certificates when you change factory, materials or production lot information.
- Keep records for at least five years, and keep copies ready for marketplace compliance requests.
For the wider picture on customs, see our guides on finding your HTS code and shipping to the US after de minimis. This article is general information, not legal advice; confirm your obligations with a licensed customs broker or attorney.
How Atronia Innovations can help
We help Chinese factories and brands launch and grow on Amazon, Walmart and TikTok Shop, from our offices in Los Angeles and Shenzhen. We can help you organize product compliance documents for marketplace listings and coordinate with your broker and logistics. Talk to our team or read our US market entry checklist.
