If your company imports consumer products into the United States, a significant new regulatory requirement will take effect on July 8. The U.S. Consumer Product Safety Commission (CPSC) now requires importers to electronically file product safety certificate information at the time a shipment enters the United States, a departure from the previous practice of providing certificates only after a shipment was flagged for examination. The new system applies broadly, with no de minimis exemption based on shipment value.

What Changed–and Why

CPSC’s electronic filing (eFiling) system is not a new substantive safety requirement. Importers have been required to hold product certificates and make them available upon request since 2008. What has changed is the timing and method of submission. Under the new system, importers must transmit Certificate of Compliance (COC) data electronically through U.S. Customs and Border Protection’s (CBP) Automated Commercial Environment (ACE) at the moment of entry. ACE is the centralized trade-processing platform already used for import and export filings.

At this time, the CPSC does not intend to request that CBP deny entry of goods into the U.S. solely for failure to file this certificate. The ACE system will send warning messages as opposed to rejection messages for missing certificate data. However, CPSC will continue to enforce certificate requirements for imported consumer products and submit requests to CBP to initiate seizure of non-compliant products. The CPSC’s stated goals are to improve the efficiency of product inspection, better target high-risk shipments, and—importantly for compliant importers—reduce inspection frequency and hold times for companies with a strong compliance record.

Of note, the new requirement does not require importers to retest existing products. No new testing or certification requirements are created by this rule. However, retesting remains required any time a material change has been made to a product’s design, manufacturing process, or source of component parts that could affect compliance.

Who Is Affected

The requirement applies to all consumer products subject to a CPSC rule, ban, standard, or regulation. Any company in the following roles should review its operations and ensure that adequate compliance measures are implemented:

• Importers bear primary legal responsibility. The importer of record must issue its own General Certificate of Conformity (GCC) or, for children’s products, a Children’s Product Certificate (CPC). Importers cannot rely on certificates issued by foreign manufacturers. Importers, however, may rely on foreign test results when issuing their own certificate, provided they exercise due care to verify their validity.
• Manufacturers and suppliers will face increased pressure to provide test reports, certifications, and manufacturing data earlier in the supply chain.
• Customs brokers are responsible for transmitting the certificate data through ACE at the time of entry, but they depend entirely on importer-provided data and do not independently validate compliance.
• Testing laboratories, IT and software partners, and legal and compliance teams will all need to adapt workflows, data systems, and oversight practices to support the new process.

There is not a de minimis exemption. Every shipment of a CPSC-regulated consumer product, regardless of value, requires an eFiled certificate. Each certificate must cover a single product—one certificate cannot cover an entire shipment or multiple product types.

How eFiling Works: Two Methods

The CPSC has approved two methods for submitting certificate data through ACE:

• Full PGA Message Set. The importer provides its broker with the full product certificate, and the broker files it directly in the CPSC Message Set portion of ACE. This method works well for importers that bring in a limited number of regulated products or do not repeatedly import the same items.
• Reference PGA Message Set (via the CPSC Product Registry). The importer pre-loads certificate data into the CPSC’s Product Registry—which supports both manual and bulk upload—and then provides the broker with reference identifiers (certifier ID, product ID, version ID) for each entry. The broker submits only those identifiers rather than the full certificate. This approach is better suited for importers who repeatedly import products covered by the same certificates, as it avoids re-filing certificate data with every shipment.

For importers using international mail, the mechanics differ: because ACE cannot process certificate data for mail shipments, certificate data must be entered into the Product Registry before the shipments arrive in the U.S.

Key Dates

Effective Date	Scope
July 8, 2026	Most imported consumer products subject to CPSC certification requirements
January 8, 2027	Consumer products imported into a Foreign Trade Zone and subsequently entered for consumption or warehousing subject to CPSC certification requirements

Penalties for Non-Compliance

Failing to furnish a certificate, or issuing a false one, is a violation of the Consumer Product Safety Act (CPSA). Violations can result in civil penalties, and in serious cases, criminal penalties and asset forfeiture. While the CPSC has stated it does not intend to initially issue entry rejections for missing eFiling data, it will adjust risk scores based on certificate data and will continue to enforce existing certificate requirements. This includes submitting requests to CBP to initiate seizure of non-compliant products.

Steps Companies Should Take Now

Companies that have not yet acted should prioritize the following:

• Review all imported products and confirm applicable HTS classifications.
• Identify which products are subject to CPSC certification requirements.
• Audit existing GCCs and CPCs for completeness and accuracy.
• Develop clear internal procedures for maintaining and supplying the required certificate data.
• Work with customs brokers to establish a data-flow protocol so that certificate information reaches brokers in time for entry filing.
• Determine the right eFiling method—full or reference—and set up the CPSC Product Registry if the reference approach makes sense for your import volume.
• Review guidance and supporting materials on the CPSC eFiling Program Overview.

The Bottom Line

The CPSC’s eFiling requirement represents a structural shift in how the agency monitors product safety at the border. Companies that adapt quickly—building reliable data pipelines between suppliers, importers, and brokers, and taking advantage of the Product Registry for repeat shipments—are better positioned not only to avoid penalties and delays but to benefit from reduced inspection frequency over time. For companies still in the process of coming into compliance, there is no better time to act.

Written with the assistance of Matt Carr and Shyann Sampson, summer associates in Husch Blackwell’s St. Louis office.