CPSC eFiling for Imported Consumer Products: 22 Data Checks

What Is CPSC eFiling?

The U.S. Consumer Product Safety Commission (CPSC) now asks importers to file certificate data online. This process is called eFiling. The final rule in the Federal Register took effect on July 8, 2026, for most regulated products. Goods that enter from a foreign trade zone have a later date, January 8, 2027 (United States, Consumer Product Safety Commission 1800).

Under this rule, the importer sends certificate data to U.S. Customs and Border Protection (CBP) at entry. The data goes into CBP's ACE system as a "PGA Message Set."

The 22 checks below help importers prepare. They fit into a normal U.S. import customs clearance plan.

The 22 Data Checks

Part 1: Does the Product Need eFiling?

1. Rule check. The importer should first confirm that a CPSC rule, ban, or standard covers the product. CPSC's Regulatory Robot can help.

2. Certificate type. A children's product needs a Children's Product Certificate (CPC). A general-use product needs a General Certificate of Conformity (GCC).

3. HTS flag. CPSC publishes a list of HTS codes that flag for eFiling. A flag is a strong hint, but the product rules give the final answer.

4. Disclaim option. If a flagged product needs no certificate, a Disclaim message is optional, but CPSC encourages it (United States, Consumer Product Safety Commission 1814).

5. Component parts. A part for further manufacturing in the U.S. does not need an eFiled certificate.

Part 2: The Seven Data Elements

CPSC lists seven required elements for a full filing ("CPSC eFiling Checklist").

6. Product ID. The ID must be unique. Accepted types include GTIN, UPC, SKU, and model number ("CPSC eFiling Checklist").

7. Citation codes. The certificate must list every rule that applies. For toys, it must list each relevant section of ASTM F963 (United States, Consumer Product Safety Commission 1813).

8. Manufacture date. The importer should give the first date of production. For a long run, the month and year are the minimum.

9. Manufacture place. This field needs the name, full address, phone number, and email of the factory.

10. Test date. This date shows the most recent test of the finished product.

11. Testing lab. The certificate names the lab that did the tests. A children's product needs a CPSC-accepted third-party lab.

12. Point of contact. This person keeps the test records. A shared team email is fine if someone checks it and replies within 24 hours (United States, Consumer Product Safety Commission 1813).

Part 3: Data Accuracy

13. One product. Each certificate covers one product only. Goods from several factories may ship together through a China warehouse and consolidation service, but each product still needs its own data.

14. Exclusions. If a product skips a test under an exemption, the certificate must cite it or explain why no test was done.

15. Clear description. The product description must be clear enough to match the goods to their certificate.

16. Current record. One record can cover repeat shipments if nothing material changes (United States, Consumer Product Safety Commission 1813). After a design change or a new test, the importer should update it.

17. True and accurate data. The certifier must confirm that the data is true and accurate. The importer stays legally responsible, even when partners enter the data (United States, Consumer Product Safety Commission 1815).

Part 4: The Filing

18. Filing method. A Full PGA Message Set sends all seven elements with each entry. A Reference PGA Message Set sends only three IDs: Certifier ID, Product ID, and Version ID.

19. Registry account. The Reference method needs a CPSC Product Registry account. The CPSC eFiling page links to the account sign-up ("eFiling"). Users can add data by web form, CSV upload, or API.

20. Partner access. The importer can let a broker or a lab upload data to the Registry.

21. Broker handoff. The broker needs the three IDs before entry, so the importer should send them early.

22. Filer and timing. The importer of record or its customs broker files the data at entry or entry summary (United States, Consumer Product Safety Commission 1815).

How Efan Can Help

Efan Logistics ships goods from China to the United States. Our team can review product details and check HS codes before shipment. Our customs clearance service works with professional brokers on each declaration. Some goods also face other agency rules, such as a TSCA import certification. We suggest that you collect certificate data early, before the cargo leaves China.