Product Registry vs ACE eFiling

United States federal · Last reviewed August 25, 2026

Product Registry vs ACE eFiling is a storage-versus-transmission distinction. The CPSC Product Registry is where an importer can create, certify, store, version, and manage product certificate data. ACE is the U.S. Customs and Border Protection system where the CPSC Partner Government Agency message is transmitted with an import entry.

The Registry does not automatically send anything to ACE. If you use a Reference PGA Message Set, you must give the broker three certificate identifiers from the Registry. If you use a Full PGA Message Set, the broker sends the required certificate data through ACE and no Registry record is required.

JurisdictionUnited StatesFederal scope

Quick answer

Product Registry

Prepare and manage certificate data

Use the CPSC system to organize Business Accounts, Product Collections, trade parties, product certificates, versions, and user permissions.

ACE

Transmit the import message

Use the CBP entry process to send either the full certificate data set or the identifiers that reference a certificate already stored in Product Registry.

The handoff

Your broker still needs filing data

Product Registry does not connect to ACE automatically. The importer must supply the broker with the correct Full PGA data or the three Reference identifiers before entry filing.

Product Registry and ACE do different jobs

Question CPSC Product Registry ACE eFiling
Who operates it? U.S. Consumer Product Safety Commission U.S. Customs and Border Protection, carrying the CPSC PGA Message Set
What is its main function? Create, certify, store, version, and manage product certificate data Transmit CPSC certificate data or certificate identifiers with the import entry
Is it required for a Full PGA Message Set? No Yes—the Full PGA data are filed through ACE
What does a Reference filing use? A certified record identified by Certifier ID, Product ID, and Version ID The same three identifiers in the Reference PGA Message Set
Does it complete the other step automatically? No; it does not communicate automatically with ACE No; the filer must submit the correct PGA Message Set
Who remains responsible? The finished-product certifier remains responsible even if a delegate enters data The responsible certifier/importer must ensure the entry references accurate certificate information

How the Full PGA Message Set works

The Full path sends certificate data through ACE without first creating a Product Registry certificate. CPSC describes seven required data elements for this route: Product ID, citation codes, manufacture date, manufacture place, product test date, testing laboratory, and point of contact.

  1. Confirm that the imported finished product requires certification. Do not infer the answer from an HTS flag alone; identify the applicable CPSC rule, ban, standard, or regulation and the finished-product certificate requirement.
  2. Build the current certificate data set. Match the product identifier, certifying party, manufacture information, testing information, citations, and recordkeeper contact to the finished product and shipment.
  3. Send the data to the broker or ACE filer. The filer maps the certificate fields to the current CPSC PGA Message Set under CBP’s CATAIR rules.
  4. Transmit with the entry. For the covered entry process, the certificate data are eFiled in ACE at entry, or when entry and entry summary are filed together.
  5. Keep the certificate and supporting records. ACE transmission does not replace the finished-product certifier’s certificate accuracy, availability, and recordkeeping duties.
When this path can fit: CPSC describes the Full PGA option as suitable where an importer handles a limited number of regulated products or does not repeatedly import the same product. That is workflow guidance, not a legal safe harbor.

How the Reference PGA Message Set works

The Reference path separates certificate storage from entry transmission. The complete certificate data are certified in Product Registry first. ACE then receives three identifiers that point to that stored record: Certifier ID, Product ID, and Version ID.

  1. Create the importer’s Product Registry Business Account. The account represents the importer or other responsible certifying entity recognized in the CPSC workflow.
  2. Organize access and data ownership. Product Collections can separate certificate data and user permissions. Importer employees and invited trade partners may receive defined roles.
  3. Enter and certify the product certificate. Data can be entered manually, uploaded by CSV, or integrated through the CPSC API. Certification must cover one finished product and the applicable current certificate content.
  4. Lock the three identifiers. Give the broker the exact Certifier ID, Primary Product ID, and Version ID for the certified record that matches the shipment.
  5. File the Reference PGA Message Set in ACE. The broker transmits those identifiers with the import entry. ACE and CPSC use them to locate the Registry certificate.
  6. Control later changes. If certificate facts change, create or select the correct current version and update the broker handoff. Do not keep referencing an obsolete Version ID.
Critical control: A certificate marked certified in Product Registry is not automatically eFiled in ACE. If the three identifiers are not transmitted in the entry, the Reference workflow is incomplete.

Who owns each task

Finished-product certifier

Owns certificate truth

The legally responsible certifier remains accountable for validity, accuracy, completeness, and availability, even when another party enters or transmits data.

Importer administrator

Controls the Registry account

The Business Account Administrator manages users, Product Collections, permissions, and the importer’s certificate environment.

Trade partner

Can assist under delegated access

A broker, manufacturer, laboratory, or other invited party may enter or manage data within the permissions granted for a Product Collection.

Customs broker or filer

Transmits the PGA Message Set

The broker maps and sends the Full data or Reference identifiers through ACE. The broker needs the correct shipment-specific handoff before filing.

Software provider

Moves and validates data

Software may support Registry API/CSV work or ACE message preparation, but its automation does not transfer the certifier’s legal responsibility or guarantee acceptance.

Control Product IDs and versions before entry

The Reference workflow depends on an exact match between the shipment and the stored certificate. CPSC permits seven Product ID types: GTIN, SKU, UPC, Model Number, Serial Number, Registered Number, and Alternate ID. The Primary Product ID becomes one of the three ACE reference identifiers.

Before building either message path, make sure the team is using the finished-product certificate rather than treating a laboratory report as the filing record. Our CPC vs laboratory test report guide explains that distinction.

Control Why it matters Check before filing
Certifier ID Links the Reference filing to the responsible certifier’s Registry account Exact spelling and account ownership
Primary Product ID Identifies the certified finished product Identifier type and value match the product, packing list, or invoice
Version ID Selects the specific certificate version Current manufacture, testing, facility, and certificate facts
Certificate status A draft record is not the certified record intended for the Reference filing Certification and attestation completed
Broker handoff Registry data do not move to ACE by themselves All three identifiers delivered through a controlled process
Supporting records Registry or ACE data do not replace required testing records Records remain accessible and retained for the required period

Know the exceptions and timing boundaries

Most covered imports

Mandatory since July 8, 2026

Certificate data for covered imported finished products are eFiled at entry through ACE using the Full or Reference PGA path.

International mail

Use Product Registry before arrival

Because CBP does not process mail-shipment entry data through ACE, current rules require covered certificate data in Product Registry before U.S. arrival.

De minimis

No value-based certificate exemption

A covered product requiring certification must have eFiled certificate data regardless of shipment value. A Disclaim message is not mandatory.

Domestic products

No ACE eFiling

Domestic certifiers still issue and make required certificates available, but the import eFiling workflow does not apply to U.S.-manufactured products.

Foreign Trade Zones

January 8, 2027 start

The later effective date applies when covered merchandise is withdrawn from an FTZ for consumption or warehousing.

Run this pre-entry failure check

Do not treat a warning-only launch posture as permission to skip filing. CPSC currently says missing PGA data will initially generate warnings rather than ACE rejects and that it does not intend to request denial solely for failure to eFile. The underlying certificate rules remain enforceable, and this posture can change.
  1. Wrong path: the team built a Registry record but the broker expects a Full data set, or the team supplied Full data while the entry is configured for a Reference message.
  2. Missing handoff: the Registry certificate is certified, but the broker never received all three Reference identifiers.
  3. Stale version: the Version ID points to certificate facts that no longer match the current product, facility, test, or manufacturing run.
  4. Uncertified record: data were entered but the required certification/attestation step was not completed.
  5. Product mismatch: the Primary Product ID does not match the identifier visible in commercial or packaging records.
  6. Responsibility gap: a provider or broker has data-entry access, but no responsible certifier owns accuracy and record availability.
  7. Scope error: the team used an HTS flag as the only legal analysis or assumed every CPSC-regulated product follows the same certificate rule.

Choose tools around the workflow, not the label

An “eFiling” product may support Product Registry data preparation, CSV generation, API integration, broker handoff, ACE PGA message creation, or several of those functions. Confirm the exact boundary before buying or integrating anything.

Next pages in this cluster: use the planned CPSC eFiling requirements guide for the complete obligation and exception analysis, and the planned CPSC eFiling software comparison for provider-level workflow coverage. Both destinations are part of the approved site map and may remain unpublished until their own evidence and QA cycles are complete. Browse the Guides hub for currently published compliance workflows.

Frequently asked questions

Does Product Registry automatically send my certificate to ACE?

No. CPSC describes Product Registry as a stand-alone repository that does not automatically communicate with ACE. For a Reference filing, the importer must give the broker the Certifier ID, Product ID, and Version ID.

Can I use ACE without Product Registry?

Yes. A Full PGA Message Set sends the required certificate data through ACE without requiring a Product Registry certificate. Product Registry is used when the entry will rely on a Reference PGA Message Set or when the mail-shipment rule requires Registry entry before arrival.

Do I file the complete certificate in a Reference PGA Message Set?

No. The complete certificate data are stored in Product Registry. The Reference PGA Message Set carries the three identifiers that point to that specific certified record.

Can my broker manage Product Registry data?

An importer administrator can invite trade partners and grant defined Product Collection roles. Delegation can cover entry, management, and—when authorized—certification, but the finished-product certifier remains legally responsible.

Does eFiling apply to domestic manufacturers?

No. The ACE eFiling requirement applies to covered imported finished products. Domestic certifiers still must issue and make required certificates available under the domestic-product rules.

Is a Product Registry account required for international mail?

For covered imported finished products arriving by international mail, current rules require the certificate data to be entered into Product Registry before arrival because ACE does not process mail-shipment entry data.

Does a warning mean the filing requirement is optional?

No. CPSC’s current initial warning posture does not repeal the eFiling or certificate requirement. Treat it as mutable enforcement guidance, not an exemption.

Sources

Sources and implementation posture last checked on August 25, 2026.

Important: This guide is general information, not legal or customs advice. Product scope, certificate duties, HTS treatment, entry type, CATAIR rules, and enforcement practice can change. Confirm the current CPSC rule, Product Registry guidance, CBP filing instructions, and shipment facts before filing.