As of July 8, 2026, the U.S. Consumer Product Safety Commission (CPSC) has officially launched its mandatory electronic filing (eFiling) program. If your company imports regulated consumer products into the United States, this change directly impacts how you submit compliance documentation at the border. Understanding the new requirements and preparing your internal processes is no longer optional, it is a condition of clearing customs.

At GLC Inc., we work closely with importers to navigate evolving trade regulations, and the CPSC eFiling mandate is one of the most significant compliance shifts we have seen in over a decade. In this article, we break down what changed, which products are affected, and the concrete steps your business should take right now.

What Is CPSC eFiling?

CPSC eFiling requires importers to electronically transmit Certificate of Compliance data to U.S. Customs and Border Protection (CBP) through the Automated Commercial Environment (ACE) at the time of entry, not after the fact, and not simply upon request. Since 2008, importers of regulated consumer products have been required to maintain Certificates of Compliance, specifically Children’s Product Certificates (CPCs) and General Certificates of Conformity (GCCs). However, those certificates previously only needed to be produced if requested by CPSC or CBP. That era is now over.

Under the new rule, certificate data must be filed proactively using a CPSC PGA (Participating Government Agency) Message Set within your customs entry. This brings CPSC in line with other government agencies, such as the FDA, USDA, and EPA, that already require electronic data submission through ACE.

Key Dates to Remember

The rollout follows a firm two-phase timeline. The general requirement took effect on July 8, 2026 for most imported regulated consumer products. A second phase kicks in on January 8, 2027, extending the mandate to products entering through Foreign Trade Zones (FTZs) that are subsequently entered for consumption or warehousing.

Importantly, this mandate applies regardless of shipment value. There is no de minimis exemption, low-value shipments and direct-to-consumer parcels are equally subject to eFiling. Importers who have relied on informal entry processes for small shipments need to update their workflows immediately.

What Data Must Be Filed?

Each entry for a regulated product must include seven core data elements drawn from your Certificate of Compliance:

• Product identification information

• All applicable CPSC rules, bans, standards, and regulations the product has been certified against

• The date the finished product was manufactured

• The place (country and city) where the product was manufactured

• The date and location of the most recent compliance testing

• Identification of each third-party testing laboratory used

• Contact information for the certificate record keeper

Each testing laboratory must be associated with the specific standards it tested against, even if that testing was performed on a component part rather than the finished product. This level of detail means importers must maintain complete, well-organized testing records, not just a summary certificate.

Which Products Are Affected?

The eFiling requirement applies to any product that already requires a certificate under existing CPSC certification rules. The rule does not expand the scope of which products need certification; it changes how that certification data is delivered to the government.

To help importers and customs brokers identify shipments likely to trigger eFiling, CPSC has published a list of approximately 600 Harmonized Tariff Schedule (HTS) codes that the agency considers high-risk or likely to contain products subject to mandatory standards. These cover a wide range of product categories including toys, children’s furniture, clothing, infant sleep products, bicycles, mattresses, fireworks, carpets, strollers, and button cell batteries, among many others.

However, CPSC has made it clear that this list is not exhaustive. An HTS code not appearing on the list does not mean a product is exempt. The importer is ultimately responsible for determining whether a given product requires a certificate and, consequently, an eFiled entry.

The 1USG Messaging Process

Any entry that includes an eFiled certificate, a CPSC PGA Message Set, will also be subject to the 1USG (One U.S. Government) Messaging process. This means CBP and CPSC will coordinate messaging on flagged entries, and importers may receive “May Proceed,” “Intensive Exam,” or “Hold” responses. Even some product categories that do not require certification may still undergo 1USG messaging, so importers should review CPSC’s full messaging guidance document to understand which of their products could be flagged.

A voluntary disclaim message option is also available. When an importer’s shipment falls under a flagged HTS code but the specific product does not require certification, filing a disclaim message may positively influence the importer’s risk score within CPSC’s system, potentially reducing the frequency of inspections and holds over time.

The CPSC Product Registry

To streamline repeated imports, CPSC has launched the CPSC eFiling Product Registry, a secure online platform where importers can pre-register certificate data and obtain a Certificate Identifier. Once registered, importers can use an abbreviated message set for future entries of the same product, reducing the volume of data transmitted each time. While the registry is optional, it is strongly recommended for companies that import the same regulated products on a recurring basis.

What Happens If You Are Not Compliant?

Shipments that arrive without accurate eFiling data face real consequences: customs holds, intensive examinations, storage fees, and potential refusal of entry. Beyond the immediate operational disruption, repeated non-compliance can damage your risk profile within CPSC’s system, leading to more frequent targeting of future shipments. In a supply chain environment where speed to market is critical, preventable delays at the port are costly, both financially and competitively.

How GLC Can Help

Navigating the eFiling mandate requires coordination between your compliance team, your testing laboratories, and your customs broker. At GLC’s Customs Brokerage Division, our fully licensed brokers are already processing eFiled entries through ACE for importers across a wide range of consumer product categories.

Whether you need help identifying which HTS codes in your product line trigger eFiling, organizing your certificate data into the required format, or registering products in the CPSC Product Registry, our team is ready to guide you through every step. We also offer supply chain consulting to help you build internal workflows that keep compliance data current and audit-ready.

Don’t let the eFiling mandate catch your shipments at the border.

Contact GLC today at [email protected] or visit our contact page to speak with a customs compliance specialist.