If you import consumer products into the United States under one of approximately 600 flagged HTS codes, new compliance rules take effect on 8 July 2026. The CPSC is mandating electronic filing of Certificate of Compliance (CoC) data at the time of customs entry for regulated consumer products. This guide covers what's changing, when it happens, and what data you need to have ready.


Key takeaways

  • From 8 July 2026, importers of CPSC-regulated consumer products must file Certificate of Compliance data electronically at the time of US customs entry via CBP's Automated Commercial Environment (ACE).
  • The existing requirement to hold a Certificate of Compliance has not changed — only how it is submitted.

  • CPSC has published a list of approximately 600 HTS codes considered likely to involve regulated products. If your products don't fall under any of these codes, this change is unlikely to affect you.

  • Two filing methods are available: a Full PGA Message Set (7 data fields submitted at time of entry) or a Reference PGA Message Set (3 fields, for products pre-registered in the CPSC Product Registry).

  • A Disclaim option applies to non-commercial gifts and components destined for further US manufacturing only.

  • For products entered from a Foreign Trade Zone (FTZ), the requirement takes effect 8 January 2027.

  • Shipments without compliant eFiling data risk holds, customs delays, and storage fees.

On this page


1. What's changing on 8 July 2026


Q: What is the CPSC eFiling requirement?


From 8 July 2026, importers of consumer products subject to CPSC mandatory safety standards must electronically file Certificate of Compliance data with US Customs and Border Protection (CBP) at the time of entry. Previously, importers were only required to hold a certificate and make it available on request. Now, the data must be submitted proactively as part of the entry filing via CBP's ACE system.


Q: Does this change which products need a Certificate of Compliance?


No. The scope of products subject to CPSC certification requirements is unchanged. If your product required a CoC before 8 July, it still does. If it did not, nothing changes. This update only affects the method of submission — electronic rather than paper or on-request.


Q: What happens if I don't eFile?


Non-compliant shipments risk holds at the border, delays in customs clearance, and potential storage or warehousing fees. CPSC intends to use eFiling data to adjust risk scores — compliant shipments will be less likely to be held for examination, while non-compliant ones will attract greater scrutiny. CPSC has also stated it will submit requests to CBP to initiate seizure of non-compliant products.


Q: What's the timeline?

  • 8 July 2026 — mandatory eFiling begins for all direct consumption and warehousing entries.
  • 8 January 2027 —  mandatory eFiling begins for products entered from a Foreign Trade Zone (FTZ).

2. Which products are affected


Q: How do I know if my products are subject to CPSC eFiling?


CPSC has published a list of approximately 600 HTS codes considered likely to involve regulated products. If your products fall under one of these codes, you are likely affected. The flagged categories include children's clothing, toys, mattresses, bicycles and bicycle helmets, ATVs, strollers, child chairs, infant sleep products, lighters, fireworks, shoes, imitation jewellery, and others. You can find the full list of affected HTS codes on the CPSC eFiling page at cpsc.gov/eFiling, as well as at the bottom of this article.


If your products don't appear under any flagged HTS code, this requirement is unlikely to apply to you. The small exception is that the HTS list is not fully exhaustive — if you know your product is subject to a CPSC mandatory rule but its HTS code isn't on the list, the obligation still applies. In that case, a Disclaim filing may be appropriate if the product genuinely falls outside CPSC jurisdiction.


Q: Does the list of flagged HTS codes change?


Yes. CPSC has confirmed the list will be updated over time. It is worth checking cpsc.gov/eFiling periodically if you import products in categories adjacent to those already flagged.


Q: Is there a tool to check whether a specific product is regulated?


Yes. CPSC's Regulatory Robot tool at cpsc.gov/eFiling allows you to enter a product description and HTS code to identify which mandatory standards apply.

3. Filing methods


Q: What are the options for submitting CoC data electronically?


There are two primary methods:

  • Full PGA Message Set — all 7 certificate data elements are submitted through ACE at the time of entry. No pre-registration required.
  • Reference PGA Message Set — full certificate data is pre-registered in the CPSC Product Registry, and only 3 reference identifiers are submitted at the time of entry. Useful for importers who ship the same products repeatedly.

Different methods can be used for different products within the same entry.


Q: Which filing method should I use?


If you import the same products regularly and are willing to maintain records in the CPSC Product Registry, the Reference method reduces the data burden at the time of each entry. If you import a wide variety of products or prefer not to pre-register, the Full method requires no prior setup but involves submitting all 7 fields per entry line.

4. Required data fields


Q: What data is required for the Full PGA Message Set?


The Full PGA Message Set requires 7 data elements per product:

  1. Product identification — a unique product identifier (GTIN, SKU, UPC, model number, serial number, or alternate identifier) plus a product name
  2. Applicable CPSC rules — the specific rules, bans, or standards the product is certified against, and any testing exclusions relied upon
  3. Certifier identification — the importer of record issuing the certificate
  4. Records contact — a contact point for accessing compliance records (job title and generic email/phone is acceptable)
  5. Manufacture date and place — month and year of manufacture, and the manufacturing location
  6. Test date and place — date and location of most recent compliance testing, including testing laboratory details
  7. Attestation — confirmation that the product complies with applicable CPSC rules


Note: each certificate must cover only one product. If a product differs materially in design, manufacturing process, or component parts from another similar product, it requires a separate certificate.


Q:  What data is required for the Reference PGA Message Set?


If your product is pre-registered in the CPSC Product Registry, only 3 fields are required at the time of entry:

  • Certifier ID — your identifier in the CPSC Product Registry
  • Product ID Number — the unique product identifier as registered
  • Certificate Version ID — the specific version of the certificate on record


Q:  Are children's products treated differently? 


Yes. For children's products, the Certificate of Compliance must be based on testing by a CPSC-accredited third-party laboratory. For general-use (non-children's) products, a reasonable testing programme is sufficient and third-party accreditation is not mandatory.

5. CPSC Product Registry


Q: What is the CPSC Product Registry?


The CPSC Product Registry is a database maintained by CPSC where importers can pre-register their product certificate data. Once registered, a product only requires the 3-field Reference PGA Message Set at the time of each entry rather than all 7 Full PGA fields


Q: Who should register in the CPSC Product Registry?


Importers who frequently import the same regulated products will benefit most from registering, as it reduces the data submitted with each entry. A Business Account Administrator must be designated to create and manage the account.


Q: How long must certificate records be kept?


Importers must retain compliance certificates and supporting test or certification records for at least five years from the certificate creation date.

6. Exemptions


Q: Are any shipments exempt from CPSC eFiling?


Yes, two categories are exempt:

  • Non-commercial consumer-to-consumer shipments — for example, personal gifts sent between individuals
  • Component parts imported solely for further US manufacturing, where the component is not sold to consumers in its imported form

For these, a Disclaim filing can optionally be submitted to indicate to CPSC that no certificate data is required. Filing a Disclaim is not mandatory but may improve an entry's risk score.


Q: Does eFiling apply to shipments sent via international mail?


International mail shipments cannot transmit PGA Message Set data through ACE. For these, importers using international mail must instead enter certificate data into the CPSC Product Registry before the shipment arrives in the United States.