United States: CPSC eFiling Requirement

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What you need to know

Starting 8 July 2026, the US Consumer Product Safety Commission (CPSC) will require electronically submission of product compliance certificate data for regulated consumer products entering the United States—through the US Customs system—at the time of customs clearance entry. This new requirement is known as CPSC eFiling.

One thing to note: there’s no low-value exemption. These CPSC eFiling requirements apply regardless of shipment value. If your product is regulated, the rule applies.


What products are affected?

The requirement applies to all finished consumer products regulated by the CPSC and require certification under 16 CFR Part 1110:

“Wearing apparel” in CPSC scope means any costume or article of clothing worn or intended to be worn by individuals. Note that items such as scarves, underwear, diapers, and bibs are considered wearing apparel.

Additionally, these CPSC’s HTS Codes will be flagged at customs entry as a signal that the product likely needs a certificate to be eFiled.

ⓘ We strongly advise you to revalidate your HTS Codes (US-specific 10-digit HS Codes) with the latest revision: 2026 HTS Revision 10

If you’re not sure whether your products fall under the scope, check your product against those resources or check with CPSC’s Regulatory Robot.


What does this mean for you?

If your product is regulated, additional information will be required for each regulated product entering the US.

Certificate of Compliance data must be provided with shipping documentation so it can be electronically transmitted via the CPSC Participating Government Agency (PGA) message set at the time of customs entry.

  • Children’s Product Certificate (CPC): Required for products designed primarily for children 12 or younger. This requires passing test results from a third-party lab accepted by the CPSC.

  • General Certificate of Conformity (GCC): Required for non-children's products (general use products) that are subject to CPSC safety rules.

⚠️ Failure to provide the required information may result in entry delays, shipment holds, examinations, or additional documentation requests.


How does CPSC eFiling work and what’s required?

CPSC eFiling is submitted through the US Customs and Border Protection’s Automated Commercial Environment (ACE).

✅ Carriers or customs brokers will do the eFiling submissions, but it’s the manufacturers’, senders’, or importers’ responsibility to provide the required information.

One of two eFiling methods is used, depending on whether a product is preregistered in the CPSC Product Registry or not.

Method 1:
Full CPSC PGA Message Set

Method 2:
Reference (Abbreviated) PGA Message Set

When this applies

Product not registered in the CPSC Product Registry

Product pre-registered in the CPSC Product Registry

What’s Required

Seven “Certificate of Compliance” data elements for each product:

1. Product identifier (i.e. Global Trade Item Number / SKU)
2. Each applicable CPSC safety rule (16 CFR part 1110)
3. Date of manufacture
4. Manufacturer / producer / assembler contact information^
5. Date of most recent compliance test
6. Compliance test facility / laboratory contact information^
7. Test records keeper / owner contact information^

^Contact information includes name, address, phone number and email address

Example: FedEx's CPSC Form for Non-registered Goods

Three data elements from CPSC Product Registry only:

1. Product ID
2. Certifier ID
3. Certificate Version ID

Best For

Occasional or one time CPSC regulated imports

Repeated imports of the same CPSC regulated products and want to streamline clearance

ⓘ We are preparing the additional fields so you can provide the three data elements of your pre-registered products easily.


GCC Exemptions for Wearing Apparel

Clothing and wearing apparel falls squarely under CPSC jurisdiction, but the administrative burden under the new eFiling system depends on whether the garment is for adults or children, and whether it's regulated or exempted from “The Standard for the Flammability of Clothing Textiles”, codified under 16 CFR part 1610, which applies to all textiles used in wearing apparel.

“Wearing apparel” in CPSC scope means any costume or article of clothing worn or intended to be worn by individuals. Note that items such as scarves, underwear, diapers, and bibs are considered wearing apparel.

There are 2 categories of products that are exempted from the General Certificate of Conformity (GCC):

1. Items listed under 16 CFR § 1610.1(c):

  • Hats that do not cover the neck, face, or shoulders;

  • Gloves that are 14 inches in length or shorter and are not attached to a garment;

  • Footwear that does not consist, in whole or in part, of hosiery and is not attached to a garment; and

  • Interlining fabrics when they are intended or sold for use as a layer between an outer shell and an inner lining.

2. Items using fabrics listed under 16 CFR § 1610.1(d):

  1. Plain surface fabrics weighing 2.6 ounces per square yard or more (88.2 grams per square meter), regardless of fiber content; and

  2. Plain and raised surface fabrics made of: acrylic, modacrylic, nylon, olefin, polyester, wool, or any combination of these fibers, regardless of weight.

What is a plain surface fabric?

A plain surface fabric is any textile fabric that does not have an intentionally raised fiber or yarn surface, such as a pile, nap, or tuft. Common examples of plain surface fabrics typically include oxford, chambray, jersey cotton, and stretch knit.

However, the manufacturing process determines whether it is a plain or raised surface fabric, so these fabrics may not always be plain surface.

What is a raised surface fabric?

A raised surface fabric is any textile fabric that has an intentionally raised fiber or yarn surface, such as a pile, nap, or tuft. Whether the product has an intentionally raised surface is determined by the manufacturing process. An example of a manufacturing process that intentionally raises the fibers would be the fabric going through an agitator that cuts and brushes the fibers on the top surface.

Common examples of raised surface fabrics include terry cloth, fleece, corduroy, and flannel.

However, the manufacturing process determines whether it is a plain or raised surface fabric, so these fabrics may not always be raised surface.

For more information, visit CPSC clothing and general wearing apparel FAQs and watch CPSC business education video.


Applicable Use of CPSC Disclaims

A Disclaim Code and Intended Use Code, may be used when the product is not subject to CPSC regulatory requirements or when CPSC data submission is not required for the specific commodity.

⚠️ We strongly advise you to revalidate your HTS Codes (US-specific 10-digit HS Codes) with the latest revision: 2026 HTS Revision 10

1. Product Not Regulated by CPSC

Disclaim Code: Disclaim A

To be used if the product is:

  • Captured by CPSC’s HTS codes AND is within CPSC’s jurisdiction, BUT no rule, ban, standard, or regulation requiring a certificate applies.
    Examples:
    ◦ Hats, scarves, gloves, footwear.
    ◦ Collectible toys intended for adults.
    ◦ Sport helmets, besides bicycle helmets.
    ◦ 15(j) products, besides drawstrings (found in 16 CFR 1120).

  • Captured by CPSC’s HTS codes BUT is outside of CPSC’s jurisdiction.
    Examples:
    ◦ Medical products similar to general-use products.
    ◦ Non-consumer use industrial equipment.

CPSC recognizes eight base codes:

  • 081.XXX: For Human Medical Use as Medical Device

  • 090.XXX: For Military Use as a Non-Food Product

  • 100.XXX: For Personal Use as a Non-Food Product

  • 130.XXX: For Consumer Use as a Non-Food Product (besides 130.001-005)

  • 155.XXX: For Commercial Assembly as a Non-Food Product

  • 940.XXX: For Compassionate/Emergency Use of a Non-Food Product

  • 970.XXX: For Export

  • 980.000: For Other Use (with Intended Use Description)

ⓘ Full list of Intended Use Codes can be found here. Base 130 is the most-used base code for CPSC because the agency’s scope is consumer products. Codes 130.000 through 130.006 are all that may be used on a full submission. Disclaim A may use any 130 sub code except 130.001–130.005 (i.e., 130.000 or 130.006).

Add the relevant codes into your Item Description. Example:

  • “Men's Baseball Hat of 100% Cotton / CPSC Disclaim A - 130.000

2. CPSC Data Not Required

Disclaim Code: Disclaim B

To be used if the product is:

  • Captured by CPSC’s HTS Codes AND is within CPSC’s jurisdiction AND a rule, ban, standard, or regulation applies, BUT CPSC is exercising enforcement discretion that no certificate is required.

  • Only certain products meet these requirements.
    Examples:
    ◦ Adult wearing apparel claiming exemption under 16 CFR 1610.1(d).
    ◦ Household refrigerators if the product displays an appropriate safety certification mark indicating compliance.

Intended Use Code:

  • 130.006: Consumer product intended for People aged 13 Years or Older

    ⓘ No other code can be used, because these above products are for consumers aged 13 years or older.

Add the exact codes into your Item Description. Example:

  • “Women’s Trousers of 100% Linen / CPSC Disclaim B - 130.006


Step-by-step of what to do

  1. Revalidate your HTS Codes against the latest revision: 2026 HTS Revision 10.

  2. Cross-check your HTS Codes against the flagged CPSC’s HTS Codes. If your HTS code is not on the list, then (hopefully) you don’t need to do anything.

  3. If you regularly ship any kind of children's products (for children under 12 years old), it is best to directly pre-register your products in the CPSC Product Registry.

  4. If you are shipping adults’ clothing or wearing apparel (for ages 13 and older) that is captured in the CPSC’s HTS Codes, add the relevant Disclaimer Code and Intended Use Code to your customs declaration. Examples:
    ◦“Boy's Hat of 100% Cotton / CPSC Disclaim A - 130.003”
    ◦“Women’s Trousers of 100% Linen / CPSC Disclaim B - 130.006”
    ⓘ See the "Applicable Use of CPSC Disclaims" section above

  5. Be specific in your Item Description about who the product is for (Women’s or Men’s). This prevents customs from assuming they are children's products (Girls’ or Boys’), as many HTS codes do not differentiate between adult and children's products.


More information

Stay current with CPSC updates. The CPSC has published FAQs, webinars, and technical guidance. It’s worth bookmarking and checking regularly as implementation details continue to be refined. For more information on the CPSC eFiling requirements, visit the CPSC eFiling Resource Center.

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