CPSC eFiling: the seven data elements that decide entry

Published 2026-11-06 · CertFiling

On July 8, 2026, the way certificates reach U.S. Customs changed. Importers of regulated consumer products must now file certificate of compliance data electronically with CBP at the time of entry, through the Automated Commercial Environment, using the CPSC Partner Government Agency message set. The certificate no longer travels on request, days after the container lands. It travels with the entry, every time, or the entry does not clear.

The rule behind the change is the CPSC final rule published January 8, 2025, amending 16 CFR Part 1110. It was approved December 18, 2024, and it changes how certificate data is filed, not which products need a certificate. Certification has been required since 2008 under Section 14 of the Consumer Product Safety Act. What changed in July is the plumbing: seven data elements, sent at entry, for every regulated product in the shipment, whatever the shipment value.

The seven elements, in the order CBP reads them

First, product identification: one identifier that matches the certificate to the finished product and no other, a GTIN, model number, SKU, UPC, serial number, registered number, or alternate identifier. Pick the one that also appears on the packaging, the packing list, or the invoice, so CPSC staff can match it fast. A product ID that exists only in the certificate is a matching problem waiting for an exam.

Second, the applicable CPSC rules, cited individually. Every rule, ban, standard, or regulation the product is certified against, each one listed separately. If an exemption or determination applies, the rule is still cited, and the exemption is noted with it. Third, the certifier: the name, full mailing address, and telephone number of the domestic manufacturer or U.S. importer certifying the product. Fourth, the contact for the person who maintains the test records, with name, address, email, and telephone.

Fifth, the date and place of manufacture, at least the month and year, plus city and country. Sixth, the date and place of the most recent compliance testing. Seventh, the testing laboratory: for children's products, each CPSC-accepted third-party lab, with name, address, and telephone. Small batch manufacturers include their CPSC registration number here instead of a lab. Seven elements, and a missing one is what produces a warning, a hold, or a higher risk score at entry.

Two ways to send them

There are two filing paths, and the choice is operational, not legal. The Full PGA Message Set sends all seven elements with every entry. It fits importers with a limited number of regulated products, or products that rarely repeat. The Reference PGA Message Set preloads the certificate data into the CPSC Product Registry and transmits three identifiers at entry: Certifier ID, Product ID, and Version ID. It fits importers who repeat the same SKUs shipment after shipment, because the data is entered once and referenced, not retyped.

The reference path has a failure mode worth naming. If the registry data changes and the reference is not updated, the entry points at a stale certificate, and the mismatch is discovered at the worst moment. The full path has the opposite failure mode: retyping seven elements per product per shipment, which is how transcription errors enter the record. Neither path is free. The right one depends on how often the same products ship, and how disciplined the data desk is about updates.

What still catches importers out

Low value shipments are not exempt. Regulated products need eFiling whatever the shipment value, and with Section 321 de minimis suspended, low value shipments go through a regular entry anyway. The old assumption that a small parcel skips the certificate process is dead twice over, and the brands still operating on it are the ones whose parcels are being held.

Products entering from a Foreign Trade Zone get a later date, January 8, 2027, for consumption or warehousing entries. That is a later compliance date, not an exemption, and the same seven elements will be due then. CPSC has published roughly 600 HTS codes that are flagged in ACE, and the list is updated over time, so a product that was not flagged in July can be flagged by December. Records are kept for five years from creation, which means the filing discipline has to survive staff turnover, not just the first quarter.

Keep reading: No de minimis exemption: why small parcels need certificates too, The certificate lifecycle: from lab report to eFile.

Frequently asked questions

When did mandatory CPSC eFiling take effect?

July 8, 2026, for most imported regulated consumer products entered for consumption or warehousing. Products entered from a Foreign Trade Zone follow on January 8, 2027. The final rule was published January 8, 2025, amending 16 CFR Part 1110.

What are the seven eFiling data elements?

Product identification, the applicable CPSC rules cited individually, the certifier's name address and phone, the test records contact, the date and place of manufacture, the date and place of testing, and the testing laboratory. All seven travel with the entry through CBP's ACE system.

What is the difference between the Full and Reference PGA Message Sets?

The Full set sends all seven elements with every entry. The Reference set preloads the data into the CPSC Product Registry and sends three identifiers at entry: Certifier ID, Product ID, and Version ID. Full fits varied shipments, Reference fits repeated SKUs.

Are low value shipments exempt from eFiling?

No. Regulated products need eFiling whatever the shipment value, and with Section 321 de minimis suspended, low value shipments go through a regular entry anyway. The certificate requirement has never had a value threshold.