CPSC eFiling since July 8, 2026: What shippers need to know about US shipments now

Electronic conformity data is mandatory for regulated consumer goods. We explain which products are affected, what information is required, and how to avoid delays.

Last Update: 17. August 2026

CPSC eFiling is now in effect

The US Consumer Product Safety Commission (CPSC) implemented mandatory eFiling on July 8, 2026. Since then, importers have been required to electronically submit the data from mandatory certificates of conformity via the US Customs and Border Protection's Automated Commercial Environment (ACE). This is done using a CPSC Partner Government Agency Message Set, or PGA Message Set.

The correct classification is crucial: The CPSC has not redefined which goods must be tested or certified. The obligation to ensure product safety and issue certificates of conformity has been in place for affected products since 2008. What is new is that the relevant certificate data no longer simply needs to be kept on file or provided upon request. It must now be submitted electronically in conjunction with the import declaration.

The current transitional situation: Warning does not mean voluntary.

According to the CPSC, ACE will not automatically reject an import during the initial phase solely because the electronic PGA submission is missing. Instead, warnings may be issued initially. However, this is neither an extension of the deadline nor a general grace period.

The existing certification requirements remain fully enforceable. Missing, incomplete, or implausible information may lead to inquiries, inspections, delays, or the withholding of goods. For non-compliant products, the CPSC may also still initiate seizures or other measures. Therefore, companies should not assume that a shipment will be processed normally despite a warning notification.

 

Which products are affected by CPSC eFiling?

This affects imported, finished consumer goods that are subject to a safety rule, prohibition, standard, or other certification requirement enforced by the CPSC. This can include both children's products and certain general-purpose products.

The guidance list published by the CPSC includes approximately 600 ten-digit US HTS codes. These include items such as toys, strollers, high chairs, cribs and other children's furniture, bicycle helmets, bicycles, certain batteries, lighters, mattresses, clothing, and other consumer goods. However, the list is explicitly not exhaustive. Conversely, a listed HTS code does not automatically mean that every product imported under that code requires a CPC or GCC.

Even small and direct shipments can be affected.

For products requiring certification, there is no exemption due to low value. CPSC eFiling therefore also applies to low-value shipments and can also affect direct deliveries to consumers. The same generally applies to used, resold, or surplus goods if they were manufactured after the respective security regulation came into effect and are imported into the US as part of a commercial transaction.

Special exceptions may apply to genuine samples imported solely for testing, development, or display purposes and not distributed to U.S. consumers. The intended use must be clearly documented. A general designation as a sample is insufficient if the goods can subsequently be sold, distributed, or used by consumers.

Special deadline for Foreign Trade Zones

A different deadline applies to goods that are initially imported into a US Foreign Trade Zone and later declared for consumption or storage. The corresponding eFiling requirements will take effect there on January 8, 2027.

CPC or GCC: Which certificate is required?

The required certificate of conformity depends on the product. Children's products generally require a Children's Product Certificate (CPC). This must be based on testing by a third-party testing laboratory accredited by the CPSC. Certain regulated general-use products require a General Certificate of Conformity (GCC). A GCC may be based on testing each product individually or on an appropriate testing program, depending on the regulation.

Not every consumer good automatically requires a CPSC certificate. First, it must be determined whether a CPSC-enforced certification requirement even applies to the specific product. A careful distinction is particularly necessary for adult goods, industrial products, medical devices, or collectibles.

What data must be submitted electronically?

There are two main methods for electronic submission. Which method is most suitable depends primarily on whether a product is imported regularly and whether the certificate data has already been stored in the CPSC Product Registry.

Option 1: Full PGA Message Set with seven data elements

With a complete PGA message set, the certificate data for the respective product is transmitted directly with the import declaration:

Product ID, for example SKU, GTIN, UPC, model or part number

all applicable CPSC rules or citation codes

Production date of the finished product

Name and full address of the manufacturing, production or assembly site

Date of the relevant product test

Name, address and contact details of the testing laboratory or testing body

Contact details of the responsible person or the body that keeps test reports and evidence

Option 2: Reference PGA Message Set via the Product Registry

Those who repeatedly import the same regulated products can pre-register the complete certificate data in the CPSC Product Registry. Upon subsequent import, only three reference identifiers are then provided to the customs agent:

Certifier ID, i.e., the identifier of the certifying body

Product ID, i.e., the unique product identifier

Version ID of the stored certificate

The Product Registry does not automatically transmit this data to ACE. The three identifiers must still be passed on to the customs agent or broker so that they can submit the Reference PGA Message Set with the import declaration. Use of the registry is not mandatory, but it can significantly reduce the workload for regularly recurring items.

Who is responsible?

The responsibility lies with the importer. Typically, the Importer of Record (IOR) is the central responsible party. Depending on the import situation, an authorized customs broker may designate the owner, buyer, or consignee as the party responsible for CPSC certification, provided they possess the necessary product knowledge.

Manufacturers, suppliers, exporters, and testing laboratories often provide the technical specifications and test documentation. The carrier or customs broker, on the other hand, transmits the data to ACE. However, this does not replace the product compliance check. Therefore, responsibility, data source, and transmission method should be clearly defined before shipment.

What applies if a CPSC certificate is not required?

A listed HTS code can also cover goods for which a certificate is not required in a specific case. In such cases, a Disclaim PGA message set with a suitable Intended Use Code can be used. The CPSC distinguishes specifically between Disclaim A and Disclaim B.

Disclaimer A: For goods that fall under an HTS code covered by the CPSC, but for which no CPSC certification requirement applies or which are outside the CPSC's jurisdiction.

Disclaimer B: Only for certain goods for which a relevant regulation generally exists, but the CPSC waives the certification requirement according to its current guidance.

According to the current CPSC FAQ, submitting a Disclaim Message Set is not generally mandatory. However, it is recommended because it can improve the risk assessment of a shipment. Furthermore, carriers or customs brokers may request such information as part of their own clearance processes. A disclaimer should never be used indiscriminately or as a substitute for a certification that is actually required.

This is how shippers should prepare properly now.

Companies shipping consumer goods to the US should not begin their process only when creating the shipment. Product-related preparation at the SKU level is advisable:

Classify products. Check product type, material, age group, intended use, and the ten-digit US Customs Tariff Number (HTSUS).

Determine CPSC relevance. Compare the HTS code with the CPSC guidance list and additionally check which specific rule, prohibition, or security standard applies.

Assign CPC or GCC certification. Clarify whether a Children's Product Certificate, a General Certificate of Conformity, or no certificate is required.

Complete test data and documentation. Ensure that manufacturing, testing, and contact information is up-to-date and clearly matches the respective product ID.

Select the submission method. Choose between Full PGA Message Set and Reference PGA Message Set via the Product Registry.

Determine the Importer of Record. Specify who is responsible for importing into the USA and who provides the certificate data to the broker or carrier.

Involve the carrier or customs agent early on. Before booking, clarify the technical method required for transmitting the data or reference identifiers.

Documentation must be maintained continuously. Changes to the product, material, production location, test report, or certificate must also be reflected in the stored data.

How is the information transmitted during a shipment?

The specific transmission method depends on the shipping provider, customs broker, and booking system. According to current customer information, UPS uses methods such as the UPS Customs Detail API, UPS.com online shipping, WorldShip batch processing, or a pre-defined parts catalog. Other carriers work with uploaded certificates, supplementary shipping documents, customer databases, or their own API fields.

A PDF copy of the CPC or GCC can serve as a data source for the carrier. However, it does not automatically replace the electronic PGA notification in ACE. Therefore, before retrieving the notification, it should be clarified which data must be entered where and whether the appointed broker has received all mandatory information.

Shipping to the USA with Paket International

If you plan to ship potentially CPSC-regulated goods to the USA via Paket International, please coordinate the shipment with our team before booking. As the transmission procedures vary depending on the carrier and customs broker, the product, HTS code, Importer of Record, and any existing CPC or GCC data should be checked in advance. You can also find general information about shipping, customs, and DDP on our website. Shipping to the USAFor a more comprehensive review of new export markets and product requirements, our Export analysis are available to support you.