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Third-party product inspection, explained
Product Inspection

CPSC eFiling from 8 July 2026: what importers file and what happens if they do not

Sources checked

Starting July 8, 2026, importers of most regulated consumer products will be required to electronically file (eFile) certificates of compliance with U.S. Customs and Border Protection (CBP), via a Partner Government Agency (PGA) Message Set, according to CPSC's Children's Product Certificate page. The Certificates of Compliance final rule (90 FR 1800) is effective on July 8, 2026, except for products and substances imported into a foreign trade zone (FTZ) and subsequently entered for consumption or warehousing, for which it is effective on January 8, 2027.

Who and what it covers

CPSC's "Does eFiling Apply to Me?" page says eFiling is required for all consumer products subject to a consumer product safety rule under the Consumer Product Safety Act (CPSA), or a similar rule, ban, standard, or regulation under any other law enforced by the Commission, that are imported for consumption or warehousing or distributed in commerce.

Two further points come from other places. 16 CFR 1110.5 provides that finished products subject to a consumer product safety rule under the CPSA, or similar rule, ban, standard, or regulation under any other law enforced by the Commission, which are imported for consumption or warehousing, or are distributed in commerce, must be accompanied by a finished product certificate. And CPSC's eFiling Resources for Importers page states that for the purposes of eFiling, the importer is considered the Importer of Record (IOR) eligible to make entry for imported finished products under the Tariff Act of 1930.

Who signs the certificate is set out in 16 CFR 1110.7(a): except as otherwise provided in a specific rule, ban, standard, or regulation enforced by CPSC, for a finished product manufactured outside of the United States that must be accompanied by a certificate as set forth in § 1110.5, the importer, as defined in this part, is the finished product certifier that must issue a finished product certificate that meets the requirements of this part.

What is filed

CPSC's eFiling FAQ lists the required data elements as the Product ID, Citation Codes, Manufacture Date, Manufacture Place, Product Test Date, Testing Laboratory, and Point of Contact.

Separately, the FAQ identifies the Certificate Identifiers as the Certifier ID, Product ID, and Version ID.

That is the transmission side. The content of the certificate itself is set by current 16 CFR 1110.11(a), which requires that each finished product certificate:

  1. identify the finished product(s) covered, using at least one unique identifier such as a global trade item number (GTIN), model number, registered number, serial number, stock keeping number (SKU), universal product code (UPC), or alternate identifier, along with a sufficient description to match the product to the certificate;
  2. state each consumer product safety rule under the CPSA, or similar rule, ban, standard, or regulation under any law enforced by the Commission, to which the product(s) are being certified, identifying separately all applicable rules, bans, standards, or regulations;
  3. identify the finished product certifier as set forth in § 1110.7, including the party's name, street address, city, state or province, country or administrative region, email address, and telephone number;
  4. identify and provide contact information for the individual maintaining the records listed in § 1110.17 on behalf of the certifier;
  5. provide the date and place where the finished product(s) were manufactured, produced, or assembled;
  6. provide the most recent date and place(s) where the finished product(s) were tested for compliance with the rule(s), ban(s), standard(s), or regulation(s) cited in § 1110.11(a)(4); and
  7. provide the finished product certifier's attestation. For eFiled certificates required in § 1110.13(a)(1), attestations are included in the Product Registry and in CPSC's PGA Message Set CATAIR Implementation Guide.

When and how it is filed

16 CFR 1110.13(a)(1) covers finished products manufactured outside the United States and offered for importation into the United States for consumption or warehousing, including finished products offered for consumption or warehousing from a Foreign Trade Zone, or finished products eligible for the de minimis duty exemption under 19 U.S.C. 1321(a)(2)(C). In those cases, the finished product certifier must eFile the finished product certificate data elements required in § 1110.11 at the time of filing the entry, or the time of filing the entry and entry summary, if both are filed together, in ACE as provided in CPSC's PGA Message Set CATAIR Implementation Guide (including revisions thereto).

The same section handles mail separately: in the case of finished products that are manufactured outside of the United States and imported by mail, the certifier must enter the certificate data elements required in § 1110.11 into CPSC's Product Registry before arrival of the product or substance in the United States.

Language is settled in 16 CFR 1110.9(a): an eFiled finished product certificate must be in the English language.

What happens if they do not eFile

CPSC's eFiling FAQ states: "At this time, CPSC does not intend to request that CBP deny entry of products into the U.S. solely based on failure to eFile certificate data via a Full PGA Message Set or a Reference PGA Message Set." It continues: "However, CPSC will continue to enforce certificate requirements for imported consumer products and submit requests to CBP to initiate seizure of non-compliant products."

Enforcement on the import side continues regardless. CPSC's Import Resources page says CPSC's Office of Import Surveillance (EXIS) works closely with U.S. Customs and Border Protection (CBP) to identify and examine imported shipments of consumer products, and that CPSC issues a Notice of Violation when there is a violation of a mandatory standard.

What is not covered

The FAQ's exclusions come with their own conditions. It says eFiling is not required for noncommercial transactions between one consumer outside the United States to another consumer in the United States. And it says consumer products that are imported only as samples—and are not intended for distribution into U.S. interstate commerce or otherwise to be used by U.S. consumers—do not need to comply with CPSC product safety requirements.

Certificates still have to be available

16 CFR 1110.13(b) requires a finished product certifier to furnish the required finished product certificate to each distributor or retailer of the finished product. 16 CFR 1110.13(c) requires certifiers to make finished product certificates available for inspection immediately, meaning within 24 hours, upon request by CPSC or CBP.

Questions people ask

Does CPSC plan to stop CBP from admitting goods if I do not eFile?

The FAQ says: "At this time, CPSC does not intend to request that CBP deny entry of products into the U.S. solely based on failure to eFile certificate data via a Full PGA Message Set or a Reference PGA Message Set." The FAQ adds that CPSC will continue to enforce certificate requirements for imported consumer products and submit requests to CBP to initiate seizure of non-compliant products.

Must the eFiled certificate be in English?

Yes. 16 CFR 1110.9(a) provides that an eFiled finished product certificate must be in the English language.

Do goods sent by mail follow the same timing?

No. 16 CFR 1110.13(a)(1) puts mail shipments in a different track: the certifier must enter the certificate data elements required in § 1110.11 into CPSC's Product Registry before arrival of the product or substance in the United States.

Sources

Checked 11 October 2026. This page is an unofficial summary and is not affiliated with the U.S. Consumer Product Safety Commission or U.S. Customs and Border Protection; the official text governs.

Inspection Guide