eFiling – CPSC’s Modern Approach for Filing Certificate Data

Gaining familiarity with the resources available on our webpage and in our Document Library such as our eFiling Quick Start Guide and Product Registry Training Videos is an excellent way to kick off participation in the eFiling voluntary stage. 

While shipments are still subject to usual CPSC examination, participation in the eFiling voluntary stage and mistakes made in voluntary filings of certificate data will not impact importers’ risk scores nor cause shipment delays. The eFiling voluntary stage is designed to support learning and testing without penalizing participants for mistakes.

Per CPSC guidance provided in the eFiling Final Rule, product certificates are required for finished products. As such, if the finished product certificate relies on testing done on component parts, such certificates must list all applicable testing laboratories and all applicable citation(s) and testing exclusion code(s) to reflect all component parts tested, along with the date the finished product was most recently tested for compliance to provide the required product testing information for the finished product certificate.  Component part test reports and finished product certificates should be periodically updated to provide reasonable assurance that product conformance has not changed. All other product testing fields such as Test URL, Test Report Key, and Test Report ID are generally optional, but importers are encouraged to provide this information when completing a finished product certificate. Importers may be required to provide information regarding optional product testing fields upon CPSC request.

At this time, CPSC does not intend to request that CBP deny entry of products into the U.S. solely based on failure to eFile certificate data via a Full PGA Message Set or a Reference PGA Message Set. To this end, CPSC does not intend initially to have the ACE system send reject messages for missing PGA data, only warning messages. However, CPSC will continue to enforce certificate requirements for imported consumer products and submit requests to CBP to initiate seizure of non-compliant products. Furthermore, CPSC intends to adjust an entry line’s risk score based on certificate data provided via a Full PGA Message Set or a Reference PGA Message Set, which should reduce holds and examinations for compliant products and better focus resources on non-compliant products. 

For further guidance, please see the Federal Register Notice for Certificates of Compliance. 

Once participants progress into phase three of the voluntary stage and are ready to transmit Partner Government Agency (PGA) Message Sets, they can transmit using one of two methods:  

• Full PGA Message Set: The importer provides their broker with the seven required product certificate data elements for the imported product and the broker files it in the CPSC PGA Message Set. The required data elements include the Product ID, Citation Codes, Manufacture Date, Manufacture Place, Product Test Date, Testing Laboratory, and Point of Contact. 
• Reference PGA Message Set: The importer pre-enters the product certificate data into the CPSC Product Registry and then provides their broker with the Certificate Identifiers to be filed in the PGA Message Set. The Certificate Identifiers are the Certifier ID, Product ID, and Version ID.

Reference PGA Message Sets are preferable if the importer repeatedly imports regulated consumer products covered by the same product certificates. By using the Product Registry, the importer can leverage manual or bulk upload features to file product certificate data in a streamlined and more efficient manner. As long as the product certificate details are identical, a product certificate can be entered in the Product Registry and referenced repeatedly as multiple shipments of the same product are imported.

No, the CPSC Product Registry serves as a stand-alone central data repository for importers’ product certificate data and does not communicate with CBP’s ACE system. Once a product certificate is entered and certified in the Product Registry, importers must communicate the three Certificate Identifiers from the product certificate to their broker, so that the Reference PGA Message Set can accurately reference the applicable product certificate in the Product Registry.

No, the CPSC Product Registry is not required to file Full PGA Message Sets.

Users have two options to bulk upload product certificate data into the Product Registry. Users can bulk upload via a Comma-Separated Values (CSV) file or Application Programming Interface (API) integration. Users can access our CSV Bulk Upload Template, User Guide for CSV Upload, and API Specifications document in the Document Library available on our webpage for additional guidance.

Participants are encouraged to review the HTS, Citation, and Testing Exclusion codes in our Document Library to best understand which codes require product certification and/or if a Disclaim is allowed. The HTS, citation, and testing exclusion codes available in our Document Library are not all-encompassing lists and only serve as guidance for the eFiling voluntary stage. For additional citation and testing exclusion guidance, we encourage you to use our Regulatory Robot and/or reach out to CPSC’s Small Business Ombudsman team at sbo@cpsc.gov. For additional guidance on HTS codes, we encourage you to work with CBP and your trade partners to better understand the HTS codes that apply to your products.

CPSC will not be flagging HTS codes for CPSC data review during the eFiling voluntary stage.  

CPSC will be flagging HTS codes for CPSC data review upon eFiling full implementation.

If the product requires product certification and a testing exclusion applies, then a testing exclusion code must be provided with the product certificate. The Product Registry includes a feature that allows users to add testing exclusion codes.

You can contact the eFiling support team via the eFiling Support Inbox at eFilingSupport@cpsc.gov.

No, Disclaim PGA Message Sets are not required. CPSC encourages importers to file Disclaim PGA Message Sets for the benefit of potentially improving their risk score.

CPSC has approved a Final Rule to implement eFiling of Certificate information for imported, regulated consumer products. Under the Final Rule, requirements impacting most imported consumer products will take effect on July 8th, 2026. Requirements impacting consumer products imported into a Foreign Trade Zone (FTZ) and subsequently entered for consumption or warehousing will take effect on January 8th, 2027. Learn more about eFiling full implementation by viewing our CPSC News Release and the Federal Register Notice.

The importer is required to submit certificate data at the time of filing entry in Customs and Border Protection’s (CBP) Automated Commercial Environment (ACE) for all merchandise withdrawn from a Foreign Trade Zone (FTZ) for consumption or warehousing. Additionally, CPSC’s final rule provides a 24-month implementation period, with an effective date on January 8th, 2027, for merchandise entered from an FTZ. This extended timeframe provides the trade with ample time to apply necessary software updates or business operation changes to comply with CPSC’s new requirements for products entered from an FTZ.

ACE already has the functionality to accept the requisite certificate data via the CPSC message set on a type 06 consumption entry for merchandise withdrawn from an FTZ. The CPSC message set can also be transmitted as part of a weekly entry submission.

Any product requiring certification must have an eFiled certificate, regardless of the value of the imported shipment. There is no Section 321 (also known as de minimis) shipment exemption for eFiling. 

Please note that Disclaim PGA Message Sets are not required for any imported shipments, including Section 321 (de minimis) shipments but CPSC encourages importers to file Disclaim PGA Message Sets for the benefit of potentially improving their risk score.

A CPSC Reference PGA Message Set requires an entry and therefore cannot be attached to a CBP manifest.

CPSC does not notify the trade of HTS code updates. CPSC is advising the trade to check the U.S. International Trade Commission (ITC) website for HTS code updates.

CPSC highly encourages importers to consider participating in the eFiling voluntary stage to be better prepared for full implementation. The eFiling voluntary stage is for importers and their trade partners to initiate the learning process, assess program readiness, and slowly ramp up eFiling testing efforts. We anticipate an initial learning curve but by progressing through each implementation phase, importers and their trade partners will be able to minimize mistakes and eFile for more products over time as they prepare for eFiling’s full implementation.

Participants can eFile for as many products as they choose. Participants can start small and build out their portfolio of products for eFiling over time.