United States federal · CPSC certificate eFiling for regulated imported consumer products · Reviewed 25 August 2026
The CPSC eFiling requirements took effect on July 8, 2026, and the question most importers need answered is narrower than “do I have to eFile?” It is: does my product require a certificate at all? If it does, 16 CFR § 1110.13 requires the certificate data to be filed electronically with the entry. If it does not, there is nothing to eFile, and CPSC does not require a Disclaim PGA Message Set.
That distinction matters because a flagged tariff code is not the legal test. Under 16 CFR part 1110, the duty attaches to finished products subject to a consumer product safety rule, ban, standard, or regulation that CPSC enforces. Tariff flags are a targeting aid layered on top of that test.
JurisdictionUnited StatesFederal scope
Read the current enforcement posture in full. CPSC says that at this time it does not intend to request that CBP deny entry solely because an importer failed to eFile certificate data, and that it does not intend initially to have ACE send reject messages for missing PGA data—only warning messages.
In the same passage, CPSC says it will continue to enforce certificate requirements for imported consumer products and submit requests to CBP to initiate seizure of non-compliant products.
Those two halves belong together. A warning at entry is not permission to skip the filing, and it is not permission to ship an uncertified product. The words “at this time” and “initially” are CPSC’s own.
Does this apply to you? Start with the certificate
Part 1110 requires a finished product certificate for finished products subject to a consumer product safety rule under the CPSA—or a similar rule, ban, standard, or regulation under another law the Commission enforces—when they are imported for consumption or warehousing or distributed in commerce.
There are two kinds of finished product certificate: a Children’s Product Certificate (CPC) and a General Certificate of Conformity (GCC). Which one applies depends on the product and the rule, not on how you file.
| Situation | Certificate required? | eFile in ACE? |
|---|---|---|
| Imported finished product subject to a CPSC rule, ban, standard, or regulation | Yes—a CPC or a GCC depending on the product | Yes, with the entry |
| Product outside CPSC jurisdiction | No | No; a Disclaim PGA Message Set is not required |
| Product within CPSC jurisdiction but no rule requiring a certificate applies | No | No; a Disclaim PGA Message Set is not required |
| Component part for further assembly in the United States, not sold or held for sale to consumers | Component part certificates are voluntary | No; § 1110.19 says component part certificates must not be eFiled in ACE |
| Product manufactured in the United States | Yes if a rule applies; domestic certifiers still issue certificates | No; the ACE import workflow does not apply to domestic products |
| Covered finished product arriving by international mail | Yes | No; enter the data in CPSC’s Product Registry before arrival |
| Covered finished product in a low-value or de minimis shipment | Yes | Yes; the rule expressly reaches products eligible for the de minimis duty exemption |
About the HTS flag list. CPSC publishes a list of tariff codes flagged for possible eFiling. Treat that list as a targeting aid that tells you when to check, not as the legal test of whether a certificate is required. Work from the applicable safety rule for the product.
The dates that apply
- July 8, 2026: eFiling took effect for most covered imported finished products.
- January 8, 2027: the requirements begin for covered merchandise withdrawn from a Foreign Trade Zone for consumption or warehousing.
- At entry: certificate data are filed when the entry is filed, or when the entry and entry summary are filed together.
- Before arrival: for products imported by mail, certificate data go into Product Registry before the product arrives in the United States.
The mail rule exists for a mechanical reason: CBP does not collect entry data for products imported by international mail, so those shipments cannot carry a PGA Message Set. Product Registry is the required channel for that case.
Who is responsible
Part 1110 assigns the certifier according to how the finished product enters commerce. For a covered finished product manufactured outside the United States, the importer is the finished product certifier unless a product-specific rule provides otherwise. For a covered product manufactured in the United States, the manufacturer is generally the certifier; a private labeler can carry that duty in the circumstances described by the rule.
For eFiling, the importer is the Importer of Record eligible to make entry. That can be an owner, purchaser, or authorized customs broker. If a broker does not have enough product knowledge to be responsible for testing and certification, the broker may identify the owner, purchaser, or consignee that authorized the entry as the party responsible for the CPSC certificate requirements.
You can delegate the work. You cannot delegate the responsibility. A finished product certifier may have another entity enter Product Registry data or certify on its behalf, but the certifier remains legally responsible for the certificate’s validity, accuracy, completeness, and availability. A broker, agent, or software platform performing the mechanics does not absorb that duty.
What goes into the filing
The filing uses data from the CPC or GCC. eFiling is a transmission requirement layered on the certification obligation; it does not replace the certificate or the evidence supporting it. For a Full PGA Message Set, CPSC identifies seven required certificate data elements:
- Product ID
- Citation codes for the applicable rules
- Manufacture date
- Manufacture place
- Product test date
- Testing laboratory
- Point of contact for the records
The revised certificate-content rule is broader than this short operational list. Section 1110.11 requires the certificate to identify the product, list each applicable rule separately, identify the certifier and records contact, give manufacture and testing details, and include the required attestation. Each certificate describes one product.
New since July 8, 2026. Revised part 1110 also requires identification of any testing exclusions relied upon. Other testing fields—Test URL, Test Report Key, and Test Report ID—are optional but encouraged. CPSC may request the supporting test records and information about optional fields. Optional at filing is not the same as unnecessary to hold.
Full vs Reference PGA Message Set
| Question | Full PGA Message Set | Reference PGA Message Set |
|---|---|---|
| What is transmitted | The required certificate data elements themselves through ACE | Three identifiers pointing to a certificate already stored in Product Registry |
| Is Product Registry needed? | No | Yes; CPSC says the certificate must be certified there first |
| What the broker receives | The full certificate data set for the shipment | Certifier ID, Product ID, and Version ID |
| Typical fit | Fewer regulated products or products not repeatedly imported | Repeat imports of the same certified products |
| Common failure | Incomplete or stale data assembled per shipment | A certified record exists, but the three identifiers never reach the filer |
Product Registry does not transmit to ACE by itself. CPSC describes the Registry as a stand-alone repository that does not automatically communicate with CBP’s system. Marking a certificate “certified” in the Registry does not file anything. If the three identifiers are not transmitted with the entry, the Reference workflow is incomplete.
Product Registry supports manual certificate entry, CSV bulk upload, and API integration, with role-based access through Business Accounts and Product Collections. Those are ways to place and manage data in the Registry. Getting the reference identifiers to ACE is a separate, deliberate handoff.
A practical filing workflow
- Identify the applicable rule for each product. Start with the consumer product safety rule, ban, standard, or regulation—not the tariff flag. This determines whether a certificate exists and whether it is a CPC or GCC.
- Confirm the product is a finished product. A component part destined for further assembly is not a finished product requiring certification, and component part certificates are not eFiled.
- Identify the certifier. Record the party legally required by § 1110.7 to issue the certificate for this product before anyone enters data.
- Assemble the current certificate data. Include any testing exclusions relied upon and make sure the supporting test records are retrievable.
- Choose the path. Full PGA can suit occasional or one-off regulated imports; Reference can suit repeat imports of the same certified products.
- If using Reference, certify the record in Product Registry. Capture the exact Certifier ID, Product ID, and Version ID that match this shipment.
- Hand the data to the filer deliberately. Send the Full data set or all three Reference identifiers through a controlled process.
- File with the entry. Use the current CPSC PGA Message Set CATAIR Implementation Guide for technical message rules.
- For international mail, load Product Registry before arrival.
- Keep the certificate and supporting records. Transmission does not replace the certifier’s accuracy, availability, or recordkeeping duties.
Pre-entry checklist
- The applicable rule is identified for every regulated line on the entry.
- Each item is confirmed as a finished product rather than a component part.
- The certifier is identified and knows it is the certifier.
- The certificate describes one product and matches the current product.
- Certificate data are current for the manufacturing run, facility, and test date.
- Any testing exclusions relied upon are identified.
- The chosen filing path matches what the broker or filer is configured to send.
- For Reference filings, all three identifiers are captured and version-correct.
- The Product Registry record is certified, not left in draft.
- The Product ID matches the product, packaging, packing list, or invoice.
- International-mail shipments are loaded into Product Registry before arrival.
- Supporting test records are retrievable if CPSC asks.
Where filings go wrong
| Failure point | What happened | Fix |
|---|---|---|
| Tariff flag treated as the rule | The team filed or skipped based on an HTS flag instead of identifying the applicable safety rule | Do the rule analysis per product and keep the reasoning |
| Path mismatch | A Registry record exists but the filer expects Full data, or Full data were sent for an entry configured as Reference | Agree the path with the filer per product line before entry |
| Missing handoff | The certificate is certified in Registry, but the identifiers never reached the filer | Treat the handoff as a controlled step and record what was sent |
| Stale version | The Version ID points to facts that no longer describe the current run, test, or facility | Create or select the correct version and reissue the handoff |
| Draft record | Data were entered, but Product Registry certification was never completed | Complete certification before quoting identifiers |
| Component confusion | A component part certificate was pushed into an ACE filing | Component part certificates are not eFiled; use the finished product certificate |
| Responsibility gap | A broker or platform holds the data, but no certifier owns accuracy and availability | Name the certifier; delegation does not move the duty |
| Mail treated as ACE | A mail shipment was left for an entry filing that never happens | Load Product Registry before arrival |
What this guide deliberately leaves to current filing instructions
We do not publish a count of flagged tariff codes because the flag is not the legal test. We also do not reproduce ACE message field formats. Part 1110 incorporates CPSC’s PGA Message Set CATAIR Implementation Guide, including later revisions. CPSC’s Document Library lists an updated CATAIR dated July 28, 2026. Your filer should work from that current guide rather than from a static field table copied into an article.
Frequently asked questions
Do all consumer products require CPSC eFiling?
No. The requirement applies to imported finished products that are subject to a consumer product safety rule, ban, standard, or regulation enforced by CPSC and therefore require a certificate. If no rule requiring a certificate applies, there is nothing to eFile.
My HTS code is flagged, but my product does not need a certificate. What do I file?
CPSC does not require a Disclaim PGA Message Set. A tariff flag is a targeting aid, not the legal test. Determine whether a CPSC rule requiring certification applies to the product.
Is there a low-value or de minimis exemption?
No. Section 1110.13 expressly reaches finished products eligible for the de minimis duty exemption under 19 U.S.C. 1321(a)(2)(C). Shipment value does not change whether a certificate is required or whether its data are subject to eFiling.
When is the data filed?
At the time of filing the entry, or when the entry and entry summary are filed together. For products imported by mail, the filing channel is CPSC’s Product Registry before the product arrives in the United States.
Do I need a Product Registry account?
Only for some workflows. An importer filing only Full PGA Message Sets does not need to use the Registry. You do need it for Reference filings, which transmit three identifiers pointing to a stored certificate, and for covered products arriving by international mail.
Does eFiling apply to products made in the United States?
No. The ACE eFiling workflow applies to covered imported finished products. Domestic certifiers still issue certificates and make them available under the domestic rules.
Do I eFile certificates for component parts?
No. Section 1110.19 says component part certificates are voluntary and are not eFiled in ACE when a component part is imported. Finished product certifiers may rely on qualifying component part certificates when issuing the finished product certificate.
If ACE only sends a warning, can I file later?
Do not treat a warning as permission to file later. CPSC’s stated posture is that it does not at this time intend to request denial of entry solely for failure to eFile, and does not initially intend for ACE to send rejects for missing PGA data. It says in the same passage that it will continue to enforce certificate requirements and submit seizure requests for non-compliant products. The posture is temporary by its own wording and does not change the certificate obligation.
Can my broker or software provider take responsibility for this?
They can perform the work. The finished product certifier remains legally responsible for the certificate’s validity, accuracy, completeness, and availability even where another party enters the data or certifies on its behalf.
Related XrdaGrid resources
Official sources
- 16 CFR Part 1110 — Certificates of Compliance
- 16 CFR § 1110.13 — Certificate availability
- 90 FR 1800 — Certificates of Compliance final rule
- CPSC — eFiling Frequently Asked Questions
- CPSC — Product Registry
- CPSC — eFiling Product Registry Guide v3
- CPSC — eFiling Document Library
- CPSC — eFiling Resources for Importers
- CPSC — mandatory eFiling implementation release
Sources and enforcement posture last checked August 25, 2026. Product scope, certificate duties, CATAIR message rules, and enforcement practice can change. Confirm the current CPSC rule, Registry guidance, and CBP filing instructions against your shipment facts before filing.
XrdaGrid publishes general information about regulatory and marketplace documentation. This guide is not legal or customs advice and does not determine whether a specific product requires a certificate, who the certifier is for a supply chain, or how a particular entry should be filed. It does not promise any entry outcome. CPSC’s stated enforcement posture is expressly temporary and may change. For a determination about your products and entries, consult a qualified professional.