�鶹ֱ��

For each consumer product subject to a rule, ban, standard, or regulation enforced by the U.S. Consumer Product Safety Commission (“CPSC”), the manufacturer or importer must certify the product’s compliance with applicable rules, bans, standards, or regulations in either a General Certificate of Conformity (“GCC”) or a Children’s Product Certificate (“CPC”). Beginning July 8, 2026,¹ importers must electronically file (“eFile”) their certificate of compliance data with the U.S. Customs and Border Protection (“CBP”) at the time of entry, regardless of the shipment size.²

While the new eFiling requirement does not change which products must be certified, it does standardize what data must be included in GCCs and CPCs, and it changes how certification information is tracked and maintained, creating new administrative requirements for importers. As with any new administrative requirement, preparation can be the difference between a seamless transition and a disruption to business operations. Importers of consumer products, are you ready? 

Filing Requirements: What Must Be eFiled and How to File It

Beginning July 8, 2026, importers must transmit seven key data elements to the CPSC electronically, through CBP’s Automated Commercial Environment (“ACE”) system:

1. The Product Identifier. GCCs and CPCs must include identification of the product being certified. The Product Identifier must be one of seven possible alphanumeric identification types: GTIN (Global Trade Item Number), SKU (Stock Keeping Unit), UPC (Universal Product Code), Model Number, Serial Number, Registered Number, or Alternate ID.  An Alternate ID is a custom string value that allows for identification of and links to information for a Trade Party.
2. The Cited Safety Rule. GCCs and CPCs must cite to each consumer product safety rule to which the finished product has been certified. Importers are responsible for identifying products subject to CPSC regulation and the regulations to which the products must be certified.
3. The Date of Manufacture. GCCs and CPCs must provide the date of manufacture for the finished product.
4. The Place of Manufacturer. GCCs and CPCs must identify the location of manufacture, production, or assembly for the finished product, including the (1) name; (2) full address; and (3) contact information of the manufacturing party.
5. The Date of Most Recent Compliance Testing. GCCs and CPCs must state the date when compliance testing most recently occurred for the finished product.
6. The Testing Laboratory’s Contact Information. GCCs and CPCs must identify the testing laboratory or laboratories used for testing in accordance with 16 C.F.R. Part 1110, including the laboratory’s (1) name, (2) full address, and (3) contact information.
7. The Point of Contact Maintaining the Records.  Contact information for the party maintaining records of test results, including (1) name, (2) full address, and (3) contact information.

Importers have two filing options for relaying this information through ACE—Full Partner Government Agency (“PGA”) Message Sets and Reference PGA Message Sets. 

If an importer selects to relay GCC or CPC information via Full PGA Message Sets, the importer must transmit the seven certificate data elements with each shipment at the time of entry. This method is generally better suited for importers handling a limited number of regulated consumer products or shipments that do not repeatedly involve the same product. Because the data must be entered for each shipment, the Full Message Set can be more time intensive. 

If an importer selects to relay GCC or CPC information via Reference PGA Message Sets, the importer can pre-file certain certificate data into the CPSC’s secure , a secure CPSC repository-database separate from CBP’s ACE. Then, at the time of entry, the importer can provide certain certificate identifiers (Certifier ID, Product ID, Version ID) in ACE, with each shipment that references the pre-stored data in the Product Registry. When product and certificate details are identical for a shipment, a certificate can be entered once in the Product Registry and referenced repeatedly for future shipments of that same product. This method is particularly efficient for repeated imports of the same product.

Deciding which method of eFiling fits your import profile and which product identifier to utilize are two of the most important planning steps that will have the greatest impact on the administrative burden of eFiling. The selected PGA Message Set type dictates whether data must be reentered each time a shipment comes through customs or whether the data may be referenced from the Product Registry. Similarly, the product identifier affects whether new data must be entered at the time of shipment or whether the Product Registry may be referenced. You do not need to use a single product identifier convention across the entire company; choose the identifier that fits each product line and supply chain and be consistent within that line. 

Thus, the selected PGA Message Set type and product identifier directly drive filing volume and workflow complexity. Importers should think critically when determining product identifiers and eFiling strategy, as it could greatly affect the administrative burden of the eFiling process.

eFiling Enforcement: How Shipments Are Selected for Review and What Each Status Means

Though the CPSC has given little indication as to how it will enforce the new eFiling requirements, it has indicated that it will initially focus on products falling within any one of approximately 600  (“HTS”) codes. The CPSC selected these codes based on its review of historical import and CPSC review data, which the CPSC suggests indicates that at least half of products in each code typically require certification or are likely high-risk imports. The flagged HTS codes cover products from all‑terrain vehicles and lawn mowers to carpets and rugs. A significant share fall within the clothing category, and several categories focus on children’s products, such as pacifiers, toys, and children’s furniture and chairs. However, this list is not exhaustive; products imported under non‑flagged codes may still require a GCC or CPC, and changes to HTS classifications can add or remove codes from the flagged list. 

Beginning July 8, 2026, the identified HTS codes will be flagged for CPSC review in ACE. When a shipment is flagged or selected for review, the CPSC will use CBP’s 1USG Messaging Program to communicate the status of review to importers, including messages stating that the shipment is: 

• Under Review. The shipment may move to the importer’s premises but cannot be entered into commerce. Where a “May Proceed” message may have been received in the past, importers may now receive “Under Review.” This generally will not impact the flow of goods unless CPSC decides whether a hold or exam is necessary.
• Hold Intact. The shipment is held for examination and cannot be moved until released. If the CPSC determines an examination is necessary, the importer may receive a hold or exam message. Investigators will then contact the importer regarding any necessary review of examination before the shipment can proceed.
• May Proceed. The shipment cleared CPSC review but may require other agency clearance.
• 1USG Clearance. CBP‑issued message confirming relevant agencies cleared the shipment. 

The CPSC has emphasized it is the importer’s responsibility to determine which products require certification, regardless of HTS flagging. How to meet that obligation is a business decision for the importer—choosing the Product identifier, selecting between Full and Reference PGA Message Sets, and integrating automated or manual processes based on scale, trade‑partner capabilities, and existing workflows, among other factors. The CPSC has made it clear that importers are expected to learn the new system and use it to file accurate certificates.

Accordingly, importers should confirm whether a CPC or GCC is required, stay current on updates to the designated HTS list, and monitor new or revised product‑specific requirements that could change certificate requirements or testing. And as always, stay apprised of regulatory changes that may affect what must be reported on certificates, whether new testing is required, and which laboratories are accredited. These elements are interconnected: eFiling is only the submission mechanism, and compliance ultimately depends on getting the underlying substantive requirements right. Proactive monitoring and coordination will reduce the likelihood of holds and help realize the efficiencies eFiling is intended to deliver.

All that said, the  that, although CPSC has been working for more than a decade to implement e‑filing, it has not developed a detailed oversight plan to ensure importers submit timely, accurate data or to specify what actions the agency will take when an importer fails to e‑file.

Act Now: It is Not Too Late to Prepare for eFiling

It is not too late to prepare for eFiling, but importers should not wait until July 2026 to begin preparations. The new eFiling framework represents a major administrative and procedural shift in CPSC-regulated imports. Any delay in implementation risks shipment delays and costly disruptions. While the CPSC’s , , and offer useful resources, successful compliance will require proactive internal planning and coordination with external partners. Importers should take steps now to prepare for eFiling, including:

1. Identify which Imported Products Require CPCs and GCCs. Once requirements are confirmed, importers should coordinate with manufacturers, testing laboratories, and other trade partners, as the accuracy and timeliness of certificate data depends on the importer’s ability to verify and transmit complete data.
2. Decide on Filing Method. Decide whether to utilize Full PGA Message Sets or Reference PGA Message Sets for individual products and coordinate with your supply-chain partners to ensure a consistent understanding of each partner’s role. Importers and their partners will need to set privacy and permission settings and data entry procedures in the Product Registry and ACE to limit the risk of unintended disclosure of sensitive supply chain information.
3. Designate a Central Point of Contact. Designate a central point of contact for eFiling with each supply chain partner to ensure a clear, consistent communication strategy.
4. Update your Compliance Program. Update your compliance program and related trainings to ensure all team members understand their role in the eFiling process.
5. Monitor for Updates from the CPSC. The CPSC may revise the list of flagged HTS codes or otherwise provide additional guidance on eFiling requirements and enforcement. Staying apprised of developments, including by attending trainings offered by the CPSC,³ will help ensure a smooth transition to compliance with eFiling requirements. 

Importers that prepare early will minimize surprises and prevent costly customs disruptions. 

For tailored guidance on how these eFiling requirements may impact your business—or to design a compliance strategy that fits your importing operations—please contact �鶹ֱ�� & Lardner’s Consumer Product Safety team.