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Understanding CPSC eFiling: New ACE Requirements for Importers

7/15/2026

The U.S. Consumer Product Safety Commission (CPSC) has implemented mandatory electronic filing requirements in ACE

The U.S. Consumer Product Safety Commission (CPSC) has implemented mandatory electronic filing requirements in ACE on July 8, 2026. 

Importers, manufacturers, and suppliers must ensure that product certification, testing documentation, and shipment information are accurate and readily available before goods are shipped.

In this guide, we'll explain what CPSC eFiling is, which products are covered, what information must be submitted, product certification requirements, and the key steps importers should take to prepare for compliance with the new ACE filing requirements.

What is CPSC eFiling?

Definition of CPSC eFiling

eFiling is a US CPSC (Consumer Product Safety Commission) initiative under which importers of regulated consumer products will electronically file (eFile) data from a Certificate of Compliance with US Customs and Border Protection (CBP) via a Partner Government Agency message set.

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 eFiling of certificate data for regulated consumer products. In 2023, the CPSC and CBP began the text 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 expansion of the test, the CPSC also proposed a new rule that would require that importers of regulated consumer products eFile Certificates of Compliance at 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.

July 8, 2026 CPSC Implements Mandatory eFiling

Effective July 8, 2026, US Customs and Border Protection (CBP) is implementing mandatory electronic filing (eFiling) for Consumer Product Safety Commission (CPSC) Certificates of Compliance through the Automated Commercial Environment (ACE) for CPSC-regulated imports(https://www.cpsc.gov/Newsroom/News-Releases/2026/CPSC-Implements-Mandatory-eFiling-for-Certificates-of-Compliance-Targeting-Dangerous-Foreign-Imports).

CPSC’s new eFiling program will apply to all imported consumer products subject to a mandatory safety standard, as set forth in the rule, including de minimis2shipments.

The eFiling program requires importers of regulated consumer products to submit compliance certificates electronically before products enter U.S. commerce. Failure to provide the required information could result in entry delays, shipment holds, examinations, or additional documentation requests.

Which Products Are Subject to CPSC eFiling?

eFiling is required for all consumer products subject to a consumer product safety rule under the Consumer Product Safety Act (CPSA), or a similar rule, ban, standard, or regulation under any other law enforced by the Commission, that are imported for consumption or warehousing or distributed in commerce. 

Examples of affected product categories include, but are not limited to:

-Children’s products:

  • Toys and games
  • Cribs, bassinets, strollers, and playsets
  • Children’s clothing and sleepwear
  • Child car seats, carriers, and highchairs

-Household goods and furnishings:

  • Furniture (e.g., sofas, mattresses, dressers, bunk beds)
  • Rugs, carpets, and window coverings
  • Portable fuel containers and candles

-Consumer electronics and electrical products:

  • Power adapters and chargers
  • Portable lighting products
  • Small household appliances
  • Battery-operated consumer devices

-Home improvement and recreation products:

  • Ladders and step stools
  • Sporting and recreational goods
  • Outdoor grills and related consumer products
  • Textiles and apparel regulated by CPSC rules:
  • Flammable fabrics
  • Upholstered furniture materials

You can see the full list below: 

If your products appear in the list and still have doubts about the applicability, importers can use the CPSC Library and/or the CPSC regulatory robot:

What data must be provided for CPSC eFiling?

Customers must support ACE filings with CPSC certificate data using one of two eFiling methods, depending on whether or not their product is preregistered in the CPSC Product

Registry:

1. Full PGA Message Set (Per-Shipment Filing):

for products not preregistered in the CPSC Product Registry, importing customers must provide seven certificate of compliance data elements:

a) Product identifier (i.e., Global Trade Item Number),

b) Each applicable CPSC safety rule certified under 16 CFR part 1110,

c) Date of manufacture for the finished product,

d) Name and address for the manufacturer, producer, or assembler,

e) Date of most recent test for compliance with applicable CPSC rules,

f) Name and address for the compliance testing facility or laboratory, and

g) Contact information for the party maintaining records of test results.

This method is recommended for customers that only import a limited number of CPSC-regulated consumer products or do not repeatedly import the same regulated product.

2. Reference (Abbreviated) PGA Message Set: products preregistered in the CPSC

Product Registry qualify for an abbreviated filing method, which only requires

customers to provide three data elements:

a) Product ID – a unique identifier for the product being certified,

b) Certifier ID – the unique identifier created by the certifying importer, and

c) Certificate Version ID – the unique identifier for the specific version of the

product certificate.

Product preregistration is optional but strongly encouraged for customers

with recurring CPSC-regulated imports covered by the same product

certificates to streamline ACE filings and reduce the likelihood of CPSCrelated clearance delays.

Product Certification Requirements

The eFiling rule does not make any changes to which products require certifications. Products must be certified if they are:

  • Finished products
  • Subject to a consumer product safety rule, ban, similar rule, standard, or regulation;
  • Imported for consumption or warehousing; or
  • Distributed in commerce

There is no de minimis exemption for eFiling. Any product requiring certification must have an eFiled certificate, regardless of the value of the imported shipment.

What Importers Should Do

CPSC staff is recommending a 12-month implementation period for the eFiling requirements. However, importers should take steps now 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:

FAQs

1: What is CPSC eFiling and when does it become mandatory?

CPSC eFiling is the electronic submission of Certificates of Compliance for CPSC‑regulated consumer products through ACE using the CPSC PGA message set. Mandatory CPSC eFiling for regulated finished consumer products applies to entries filed on or after July 8, 2026.

2: How can I determine if my product is regulated by the CPSC?

The CPSC provides a product compliance tool called the Regulatory Robot to help customers determine which CPSC rules apply to each product and what certification requirements are needed. Use of the Regulatory Robot is recommended for compliance planning.

3. Does eFiling apply to used products that were manufactured after a CPSC rule, ban, or standard went into effect?

Yes. If a used product was manufactured after the effective date of a CPSC rule, ban or standard, a certificate is required and if the product is imported as part of a commercial transaction, eFiling also applies. Commercial transactions include, but are not limited to, business-to-business, business-to-consumer and consumer-to-consumer sales.

If a product was previously required to be certified, pursuant to the Consumer Product Safety Improvement Act of 2008 or the CPSC implementing regulation, importers must continue to provide the required certificate information through eFiling.

4. Does eFiling apply to resold or overstock products?

Yes. Regulated, finished consumer products subject to a CPSC rule, ban or standard that are to be distributed in commerce must comply with CPSC’s testing and certificate import requirements, including eFiling. This includes both resold products and overstock products.

5: What information must customers provide when importing CPSC-regulated products?

Customers must provide certificate data electronically in ACE by either:

  • 01. Submitting full certificate details for each shipment with seven required data elements (recommended for customers that only import a limited number of CPSC-regulated products or do not repeatedly import the same regulated product), or
  • 02. Using preregistered product information from the CPSC Product Registry to submit a shorter reference filing with only three data elements (recommended for customers that regularly import CPSC-regulated products to streamline clearance).

6. What if my HTS code flags for CPSC, but my product does not require a certificate?

You should provide the appropriate disclaim code (A or B). While not mandatory, disclaim codes support CPSC review and may reduce delays.

7. What happens if required CPSC data is missing?

Shipments may be delayed if required electronic information is not provided with the shipment documentation. Customers are responsible for ensuring accurate certificate information is available at the time of entry to support ACE filings.

 

Resources: 

CBP CSMS #68290359 

https://content.govdelivery.com/bulletins/gd/USDHSCBP4120737?wgt_ref=USDHSCBP_WID

GET_2 16 CFR Part 1110 – CPSC Certificates of Compliance

https://www.ecfr.gov/current/title-16/chapter-II/subchapter-B/part-1110

CPSC eFiling Program

https://www.cpsc.gov/eFiling

CBP / CPSC eFiling Implementation Guide

https://www.cpsc.gov/s3fs-public/efiling-catair-igv2.3_final.pdf?VersionId=6e_z3rfMAFpM6my5fHsJ8B3186NDEyVd

CPSC Product Registry

https://www.cpsc.gov/eFiling-CPSC-Product-Registry

CPSC eFiling Product Registry User Guide

https://www.cpsc.gov/s3fspublic/eFiling_Product_Registry_User_Guide_V3.pdf?VersionId=z.UYpJQA04Bc88CqnyD7Eu M1YobhKHHq

 

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