ComplyMyImport guide
CPSC eFiling Guide for Importers
CPSC eFiling is the electronic filing of certificate-of-compliance data for imported products regulated by the US Consumer Product Safety Commission. Under the final rule updating 16 CFR part 1110, requirements affecting most imported consumer products take effect July 8, 2026. Products entered for consumption or warehousing from a Foreign Trade Zone have a January 8, 2027 effective date.
The eFiling requirement does not eliminate the need for accurate testing, applicability analysis, and certification. It changes how certificate data is transmitted in connection with an import entry.
The two CPSC eFiling paths
Importers and their filing partners can use a Full PGA Message Set or a Reference PGA Message Set.
With a Full PGA Message Set, the required certificate data elements are transmitted through US Customs and Border Protection's Automated Commercial Environment, or ACE, as part of the entry process.
With a Reference PGA Message Set, certificate data is first entered into the CPSC Product Registry. The importer then provides the broker with the Certifier ID, Product ID, and Version ID to reference in the entry filing. This approach can support repeated imports of products covered by valid certificate data.
Certificate data needed for eFiling
CPSC materials describe seven required categories of certificate data:
- Finished-product identification
- Applicable citation codes
- Manufacture date
- Manufacture location and manufacturing-party details
- Most recent product test date
- Testing-laboratory details
- Contact details for the party maintaining test records
These fields should be assembled from reviewed evidence. A broker should not have to reconstruct product compliance conclusions from disconnected emails and PDFs immediately before entry.
Product Registry submission and ACE filing are different events
The CPSC Product Registry and CBP ACE serve different parts of the workflow. Storing certificate data in the Product Registry does not mean a customs entry has been filed or accepted. For a Reference PGA Message Set, the importer supplies certificate identifiers and the customs broker or other authorized filer transmits the entry data through ACE.
Operational records should therefore distinguish at least three states:
- Certificate data accepted or stored by the CPSC Product Registry
- PGA Message Set transmitted by the broker or authorized filer
- Entry response received through CBP ACE
Combining those steps into a single status can hide a failed handoff or an incomplete entry.
A practical importer readiness workflow
Start with the product, not the shipment. Confirm the product identifier, responsible importer, factory, manufacturing date, applicable rules, test evidence, testing facility, and recordkeeper. Resolve conflicts before preparing the filing data.
Next, have an authorized representative approve the certificate. If using the Product Registry, submit the approved certificate data and retain the returned identifiers. Then provide the broker with the identifiers or complete Full PGA data, along with shipment context and clear ownership for resolving questions.
Finally, reconcile the broker's transmission status and entry response. Keep certificate versions, Product Registry identifiers, broker packages, and subsequent corrections connected to the product record.
How ComplyMyImport supports eFiling preparation
ComplyMyImport helps importers organize evidence, prepare reviewed certificate data, track Product Registry references, and produce a broker-ready handoff. It does not issue certificates automatically and does not replace the customs broker. The customer remains responsible for compliance and certificate approval, while the authorized filer remains responsible for the ACE transmission.
This guide is general educational information and is not legal or customs advice. Confirm current requirements with CPSC, CBP, your customs broker, and qualified counsel.
Official resources
- CPSC eFiling guidance: cpsc.gov/eFiling
- CPSC certificate and eFiling update: cpsc.gov/Business--Manufacturing/Business-Education/Business-Guidance/Certificates
- CBP Automated Commercial Environment information: cbp.gov/trade/automated