Update, September 27, 2026: CPSC eFiling is now in force. Since July 8, 2026, certificate data for products that need a Children’s Product Certificate or a General Certificate of Conformity has to be filed in ACE at the time of entry; for goods imported into a Foreign Trade Zone, the date is January 8, 2027, which is still ahead. See CPSC’s eFiling FAQ for the official timeline.
CPSC eFiling in Brief
A significant compliance change took effect on July 8, 2026 for importers of regulated consumer products entering the United States.
Since July 8, 2026, the U.S. Consumer Product Safety Commission (CPSC) has required mandatory electronic filing (eFiling) of product safety certificate data through U.S. Customs and Border Protection's Automated Commercial Environment (ACE).
While the underlying certification requirements are not new, the way compliance information is transmitted to regulators has changed. Importers that are not prepared may face shipment delays, increased costs, enforcement actions, and potential disruptions to their supply chains.
If you have not yet reviewed your compliance readiness, do it before your next regulated shipment.
What Changed on July 8?
The CPSC's eFiling program requires importers to electronically transmit product certificate data at the time of entry through ACE.
The requirement applies to products that require either:
A Children's Product Certificate (CPC)
A General Certificate of Conformity (GCC)
Historically, importers were required to maintain these certificates and provide them when requested. Under eFiling, key certificate data must be transmitted electronically as part of the import entry process.
What changes is the transmission method.
What does not change is the responsibility to ensure products comply with all applicable CPSC safety requirements.
Which Products Are Affected?
The requirement applies broadly across regulated consumer goods entering the United States.
Examples may include:
Toys and children's products
Consumer electronics
Furniture and home furnishings
Apparel and textiles
Sporting goods
Household products subject to CPSC regulations
Importers should review their product portfolio carefully to determine which products require certification and whether a CPC or GCC applies.
CPC vs. GCC: Understanding the Difference
Children's Product Certificate (CPC)
A CPC is required for products designed or intended primarily for children 12 years of age or younger.
Examples include:
Toys
Children's apparel
Nursery products
Children's furniture
For CPCs, testing must be performed by a CPSC-accepted third-party laboratory before certification can be issued.
General Certificate of Conformity (GCC)
A GCC applies to non-children's consumer products that are subject to applicable CPSC rules, bans, standards, or regulations.
Examples may include:
Adult apparel
Furniture
Household products
Certain consumer electronics
For GCCs, manufacturers and importers may generally rely on a reasonable testing program unless a specific regulation requires third-party testing.
Determining the correct certificate type is one of the most important steps in preparing for eFiling compliance
Three Actions for Importers
1. Confirm Which Products Require Certification
Many companies already maintain compliance documentation, but not all organizations have reviewed whether their certificates are complete, current, and ready for electronic transmission.
Importers should verify:
Which products require CPCs
Which products require GCCs
Whether testing records remain current
Whether certificate information is accurate and readily accessible
2. Verify Customs Broker Readiness
The success of eFiling depends on accurate data transmission through ACE.
Importers should confirm with their customs broker:
Their readiness to support CPSC eFiling
What certificate data will be required
How information will be collected and maintained
Whether any process changes are still needed
Waiting until shipments are already in transit can create unnecessary risk.
3. Complete Testing and Product Registry Requirements
Importers should review any applicable testing, certification, and Product Registry requirements before the next regulated shipment.
This includes confirming:
Required testing has been completed
Certificates are up to date
Supporting documentation is available
Internal compliance responsibilities are clearly defined
Preparation reduces the likelihood of shipment disruptions.
What Happens If You're Not Ready?
The most immediate consequences are operational.
Incomplete, inaccurate, or missing certificate information may result in:
Cargo holds
Delayed release of goods
Refused entry in certain circumstances
There may also be enforcement consequences.
Under current CPSC authority, civil penalties can reach up to $120,000 per violation and $17,150,000 for a related series of violations (the inflation-adjusted maximums in effect since January 1, 2022, 86 FR 68244), subject to statutory limitations and enforcement considerations.
CPSC has also stated that incomplete or inaccurate eFiling data alone — even without an underlying product safety violation — can result in shipment holds and examinations.
For importers managing high-volume consumer goods programs, preparation is significantly less expensive than remediation.
Special Considerations for Foreign Trade Zone Users
The implementation timeline is different for Foreign Trade Zone (FTZ) entries.
For products admitted into FTZs, mandatory compliance begins January 8, 2027.
Although that deadline provides additional time, importers should avoid delaying implementation efforts. Early preparation allows organizations to identify process gaps, coordinate with brokers, and establish reliable compliance workflows before the requirement becomes mandatory.
Frequently Asked Questions
Is this a new certification requirement?
No. Product certification requirements remain unchanged. The new requirement concerns the electronic transmission of certificate data through ACE.
Does every imported product require eFiling?
No. The requirement applies only to products that require a Children's Product Certificate or General Certificate of Conformity under applicable CPSC regulations.
Can my customs broker file the information for me?
In many cases, customs brokers will transmit certificate data through ACE. However, importers remain responsible for ensuring the information provided is accurate and complete.
What should importers do first?
Begin by identifying which products require CPCs or GCCs, then confirm your customs broker's readiness to support electronic filing before your next regulated shipment.
The Bottom Line
The July 8, 2026 CPSC eFiling requirement is an important operational change for importers of regulated consumer products.
Organizations that are prepared can minimize disruption, maintain cargo flow, and reduce compliance risk. Those that wait until shipments are already moving may face avoidable delays, additional costs, and enforcement exposure.
If your company imports regulated consumer goods into the United States, review your certification processes, coordinate with your customs broker, and make sure every regulated entry carries the required certificate data.
Sources: CPSC Certificates of Compliance final rule (16 CFR Part 1110; 90 FR 1800, January 8, 2025) and official CPSC eFiling guidance available at cpsc.gov/efiling.
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