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Beginning July 8, 2026, importers of regulated consumer products must electronically file certificate of compliance data with U.S. Customs and Border Protection (CBP) at the time of entry, through the Automated Commercial Environment (ACE). This requirement, established by CPSC’s Final Rule on Certificates of Compliance (amending 16 CFR Part 1110), applies regardless of shipment size. For consumer products entering through a Foreign Trade Zone, the requirement begins later, on January 8, 2027.
This guide explains what is changing, what is not, the data importers must transmit, the two filing methods available, and where the importer’s responsibility sits. Full program details are available on the CPSC eFiling program page.
What is CPSC eFiling?
CPSC eFiling is a U.S. Consumer Product Safety Commission program that requires importers of regulated consumer products to transmit certificate of compliance data electronically to CBP through ACE, at the time of entry, using a Partner Government Agency (PGA) Message Set. It replaces the prior practice in which certificates were produced only after a shipment was stopped and the data was requested.
What is changing — and what is not
The distinction matters, because it is the source of most confusion. The eFiling rule does not change which products must be certified, and it does not introduce new testing or certification standards. What it changes is how certificate information is transmitted, tracked, and maintained.
The data that has long lived on a General Certificate of Conformity (GCC) or a Children’s Product Certificate (CPC) must now be transmitted electronically at entry, rather than produced only on request. In practical terms, certificate data must be ready, structured, and accurate before goods arrive — not assembled after the fact.
The seven required data elements
Under the rule, GCCs and CPCs must carry seven standardized data elements for electronic transmission. Detail on each is available in the CPSC eFiling FAQ.
1. Product Identifier
One of seven accepted types: GTIN, SKU, UPC, Model Number, Serial Number, Registered Number, or Alternate ID.
2. Cited Safety Rule
Each consumer product safety rule the product is certified to.
3. Date of Manufacture
4. Place of Manufacture
Name, full address, and contact information.
5. Date of Most Recent Compliance Testing
6. Testing Laboratory Contact Information
Name, full address, and contact information.
7. Point of Contact Maintaining the Records
Name, full address, and contact information.
The two filing methods: Full vs. Reference PGA Message Set
CPSC provides two methods for transmitting certificate data through ACE. The right choice depends on a company’s exposure to CPSC filings and how often it imports the same products.
| Full PGA Message Set | Reference PGA Message Set | |
|---|---|---|
| How it works | Transmits all seven data elements with each shipment at the time of entry. | Certificate data is pre-filed into the CPSC Product Registry; at entry, the filing references stored identifiers rather than re-entering full data. |
| Best suited for | Importers handling a limited number of regulated products, or shipments that do not repeatedly involve the same item. | Importers with repeated imports of identical products, where a certificate can be entered once and referenced going forward. |
| Administrative burden | Full data entered each time. | Can be meaningfully reduced for repeat imports. |
| Important caveat | Data travels with every entry by design. | The Product Registry does not communicate with ACE automatically; reference identifiers must still be provided at each entry. |
What Western Overseas needs to file under the Reference method
When Western Overseas prepares entries using the Reference PGA Message Set, we need three identifiers from the importer’s Product Registry record in order to build the reference into the filing.
As Donna Armel, Compliance Director at Western Overseas, explains: “When we file under the Reference PGA Message Set, we need three identifiers from the importer’s Product Registry record to complete the filing accurately at entry: the Certificate ID, the Product ID, and the Version ID. Importers who want help generating and confirming that information can use the Regulatory Robot on CPSC’s website, or work through the walkthroughs on the CPSC’s YouTube channel. The earlier those three identifiers are in hand, the smoother the first filings go.”
The three identifiers, at a glance:
- Certificate ID
- Product ID
- Version ID
Where the importer’s responsibility sits
CPSC has been clear that it remains the importer’s responsibility to determine which products require certification, regardless of whether a product’s Harmonized Tariff Schedule (HTS) code is among the roughly 600 codes the agency has flagged for review. A flagged code does not automatically mean a product requires certification, and a product under a non-flagged code may still require a GCC or CPC. The flagging is a review mechanism, not a substitute for the importer’s own determination.
This is consistent with how customs entries already work. As with classification, valuation, and duty, the legal obligation to declare accurate information rests with the importer of record. Accurate, complete certificate data filed on time is what keeps regulated shipments moving without holds, examinations, or storage costs.
What importers should do before July 8
The most useful preparation is straightforward:
- Confirm which imported products require a GCC or CPC.
- Decide which filing method fits each product line.
- Make sure certificate data is complete and current.
- For products using the Reference method, secure the Certificate ID, Product ID, and Version ID from the Product Registry now.
Western Overseas works alongside importers of regulated cargo every day. Approximately half of the cargo we handle is regulated by partner government agencies, and process discipline around requirements like this one is built into how we clear shipments. We can help you understand how the eFiling requirement applies to your shipments, coordinate the transmission of your certificate data through ACE, and align it with your customs entries. Learn more about our customs brokerage services or speak with our compliance team about your regulated imports.
Frequently asked questions about CPSC eFiling
When does CPSC eFiling start?
CPSC eFiling begins July 8, 2026 for most regulated consumer products. For consumer products entering through a Foreign Trade Zone, it begins January 8, 2027.
Does eFiling create new testing or certification requirements?
No. The rule does not change which products must be certified or introduce new testing standards. It changes how existing GCC and CPC certificate data is transmitted, tracked, and maintained — electronically, at the time of entry, through ACE.
What data must be filed?
Seven standardized data elements: product identifier, cited safety rule, date of manufacture, place of manufacture, date of most recent compliance testing, testing laboratory contact information, and the point of contact maintaining the records.
What is the difference between the Full and Reference PGA Message Set?
The Full PGA Message Set transmits all seven data elements with each shipment at entry. The Reference PGA Message Set lets importers pre-file certificate data into the CPSC Product Registry and reference stored identifiers at entry, which can reduce administrative burden for repeat imports. The Product Registry does not communicate with ACE automatically, so reference identifiers must still be provided at each entry.
What does my customs broker need to file under the Reference method?
Western Overseas requires three identifiers from the importer’s CPSC Product Registry record: the Certificate ID, the Product ID, and the Version ID.
How do I know if my product requires certification?
It is the importer’s responsibility to determine which products require certification. CPSC has flagged roughly 600 HTS codes for review, but the list is not exhaustive: a flagged code does not automatically require certification, and a non-flagged code may still require a GCC or CPC.
Western Overseas Corporation provides compliance and operational guidance as your customs broker and freight forwarder. For binding legal advice we recommend working directly with a licensed customs attorney.
