The CPSC EFiling Deadline Is Here!

Summary: On December 18, 2024, the CPSC voted to approve a Final Rule requiring importers of regulated consumer products to electronically file Certificate of Compliance data at the time of entry. The rule takes effect July 8, 2026, for most imported consumer products. This article covers what the CPSC eFiling requirement means for importers, and the steps businesses should take now to ensure compliance before the deadline. 

On July 8, 2026, the CPSC’s mandatory eFiling requirements take effect for most imported consumer products. That means importers can no longer wait to be asked for a Certificate of Compliance. These certificates must now be electronically filed in CBP’s Automated Commercial Environment (ACE) at the time of entry, not after the fact.  

Importers that are not compliant with the applicable effective date may experience delays in the release of their shipments and increased scrutiny by CPSC at the port of entry. For products entering from a Foreign Trade Zone, the compliance date is January 8, 2027. 

CPSC’s eFiling Proposal 

Since 2008, importers have been required to maintain Certificates of Compliance stating that the product they are importing meets all applicable safety standards. However, these certificates did not need to be filed at the time of import.

In June 2022, CPSC announced a Beta Pilot test with CBP for the eFiling of certificate data for regulated consumer products. In 2023, the CPSC and CBP began the test with 38 importer participants. In December 2023, the agencies published a notice expanding the Beta Pilot test to include up to 2,000 additional importer participants and to extend the test for up to three years. In announcing the expansion of the test, the CPSC also proposed a new rule that would require that importers of regulated consumer products e-file Certificates of Compliance at the time of import

On November 22, 2024, the CPSC’s General Counsel circulated a staff briefing memorandum recommending approval and publication of a final rule implementing the eFiling proposal.

Finally, on January 8, 2025, CPSC issued a final rule adopting the eFiling proposal. 

eFiling Requirements 

The eFiling rule imposes new requirements for how importers manage product certificate data, not which products require a certificate. Any consumer product that is subject to a CPSC rule, ban, standard, or regulation will continue to require a Certificate of Compliance, which will be eFiled at the time of entry.

Importers will be required to transmit Message Set data into CBP’s Automated Commercial Environment (ACE) system at the time of entry.
 

There are two options to transmit this data: 

1. Full PGA Message Set: The importer provides their broker with the full product certificate for the imported product, and the broker files it in the CPSC PGA Message Set. 
2. Reference PGA Message Set: The importer pre-enters the certificate data into the CPSC Product Registry and then provides their broker with certificate identifiers to be filed in the PGA Message Set. 

What Importers Should Do 

If your business imports consumer products subject to CPSC regulation and you haven’t updated your compliance processes yet, the time to act is now. Importers should take steps to familiarize themselves with the eFiling requirements and ensure they are prepared to file the required information.

The CPSC has published a variety of resources to assist importers in implementing this new requirement: 

• eFiling Quick Start Guide 
• eFiling Document Library 
• eFiling Product Registry Guide 
• eFiling Implementation Guide 
• eFiling FAQs 

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.