CPSC eFiling: Which Products Need a Certificate of Compliance in ACE, and What Your Broker Needs
Chen Cui Co-Founder of GingerControl CPSC eFiling requires the importer of a CPSC-regulated finished product that must be certified to transmit certificate of compliance data in ACE with the entry. It applies to most imports from July 8, 2026, and to goods entered from a foreign trade zone from January 8, 2027, under 16 CFR part 1110. The filer sends either a Full PGA Message Set with seven data elements, or a short Reference PGA Message Set pointing to CPSC's Product Registry. For a consumer goods importer with 2,000 SKUs, the work is per product: one certificate, one product, data ready before the broker files.
Next step:Check every deadline on one entry
In this post
- What does CPSC eFiling require at entry?
- When does the requirement apply, and what changes for foreign trade zone entries?
- Which products need a General Certificate of Conformity or a Children's Product Certificate?
- What are the seven certificate data elements, and where does each one come from?
- Full PGA Message Set or Reference PGA Message Set: which should you use?
- Does the CPSC HTS list tell you which products need a certificate?
- What happens at entry when the certificate data is missing?
- How do you get certificate data ready before the broker asks?
- Where certificate data fits in your product records
- References
What does CPSC eFiling require at entry?
CPSC eFiling requires certificate of compliance data to travel with the entry in ACE, not sit in a file waiting for a request. CPSC's final rule, Certificates of Compliance (90 FR 1800, January 8, 2025), was issued "in consultation with U.S. Customs and Border Protection" and "implements, for importation of products and substances regulated by CPSC, electronic filing of certificates (eFiling) with CBP" [1].
The operative text is 16 CFR 1110.13(a)(1). For finished products made outside the United States and offered for consumption or warehousing, including from a foreign trade zone, the certifier "must eFile the finished product certificate data elements required in § 1110.11 at the time of filing the entry, or the time of filing the entry and entry summary, if both are filed together" [3]. Goods imported by mail follow a different route: the data goes into CPSC's Product Registry "before arrival of the product."
Three rules in the same part shape the work:
- One product per certificate. Section 1110.13(a) says "Each finished product certificate must describe only one product."
- English only. Under 16 CFR 1110.9(a), "An eFiled finished product certificate must be in the English language."
- The importer certifies. Under 1110.7(a), for a product made abroad, "the importer, as defined in this part, is the finished product certifier." The rule defines importer as the importer of record, who "may be an owner, purchaser, or authorized customs broker," and lets a broker acting as importer of record name the owner, purchaser or consignee as the responsible party in the PGA Message Set [1].
CPSC's July 8, 2026 announcement says the program "creates no new testing, certification, or compliance obligations" [8]. What changed is where the certificate lives and when CPSC sees it.
When does the requirement apply, and what changes for foreign trade zone entries?
The requirement applies from July 8, 2026 for most imported products and from January 8, 2027 for products entered from a foreign trade zone. The original rule listed two "effective dates." In September 2025 CPSC published a technical correction (90 FR 45917) because the Office of the Federal Register requires one effective date. The corrected text sets one effective date, July 8, 2026, and two applicability dates, and states that it "has no substantive effect on the dates by which products subject to the final rule must be in compliance" [2].
| Import path | Date or rule | Source |
|---|---|---|
| Finished products entered for consumption or warehousing (not via FTZ) | July 8, 2026 | 90 FR 1800; 90 FR 45917 |
| Products imported into an FTZ, then entered for consumption or warehousing | January 8, 2027 | 90 FR 1800; 90 FR 45917 |
| Products imported by mail | Data entered in the Product Registry before arrival | 16 CFR 1110.13(a)(1) |
| Low-value shipments | No Section 321 exemption for eFiling | CPSC eFiling FAQ |
Bottom line: For FTZ operators and the importers who use them, January 8, 2027 is the date to plan against, and the work behind it is the same as everyone else's: certificate data per product, ready before the entry for consumption is filed. A search of the Federal Register on October 15, 2026 found no later CPSC document moving either date.
The low-value row deserves attention. CPSC's eFiling FAQ states: "Any product requiring certification must have an eFiled certificate, regardless of the value of the imported shipment. There is no Section 321 (also known as de minimis) shipment exemption for eFiling" [9].
Which products need a General Certificate of Conformity or a Children's Product Certificate?
A product needs a certificate when it is a finished consumer product subject to a CPSC rule, ban, standard or regulation. 16 CFR 1110.5 says such products "must be accompanied by a finished product certificate." The definitions in 1110.3 name two types: the General Certificate of Conformity (GCC), issued under section 14(a)(1) of the Consumer Product Safety Act, and the Children's Product Certificate (CPC), issued under section 14(a)(2) and part 1107 [3].
The dividing line is age. Under 16 CFR 1200.2, a children's product is "a consumer product designed or intended primarily for children 12 years of age or younger," judged on four factors together: the manufacturer's reasonable statement of intended use, how the product is represented in packaging and advertising, whether consumers commonly recognize it as intended for a child 12 or younger, and CPSC's Age Determination Guidelines [4]. The same section notes that a label alone "is not considered to be determinative."
| Question | General Certificate of Conformity | Children's Product Certificate |
|---|---|---|
| Which products | Covered consumer products not primarily intended for children 12 or younger | Covered products designed or intended primarily for children 12 or younger |
| Statutory basis | CPSA section 14(a)(1) | CPSA section 14(a)(2) and 16 CFR part 1107 |
| Lab reported in the message set | The ITL-only rule does not apply; a lab that is not CPSC-accepted (LAB) is a listed option | Only an independent third party lab (ITL) may be reported |
| PG01 processing code, Full PGA Message Set | FGC | FCP |
| Records retention | Five years from certificate creation (1110.17) | Five years from certificate creation (1110.17) |
Bottom line: For product compliance leads at toy, juvenile, apparel and home goods importers, the GCC or CPC call is made per SKU before the first shipment. A product that drifts into children's styling can move from GCC to CPC, and with it from any lab to a CPSC-accepted third party lab.
The testing rows come from two places. 16 CFR 1107.20(a) requires manufacturers to submit children's product samples "to a third party conformity assessment body for testing to support certification" [5]. CPSC's eFiling Implementation Guide then encodes that in the data: "If 'FCP' is used as the Government Agency Processing Code in PG01, then only an Independent Third Party Lab 'ITL' can be reported" [6].
Two product groups fall outside the eFiling requirement. Component parts first: 16 CFR 1110.19 states that "Component part certificates must not be eFiled in ACE upon importation of a component part." Products CPSC has placed under enforcement discretion second: the implementation guide lists adult wearing apparel claiming the exemption in 16 CFR 1610.1(d)(1) or (d)(2), and household refrigerators that display an appropriate safety certification mark, as products that may use Disclaim B [6].
What are the seven certificate data elements, and where does each one come from?
The seven elements are set by 16 CFR 1110.11, and CPSC's implementation guide states that filers "will file, at a minimum, the seven Certificate of Compliance data elements" for regulated finished products [6]. Each one has an owner somewhere in the supply chain, and few of them are the person who files the entry.
| Element (16 CFR 1110.11) | What the rule asks for | Who usually holds it |
|---|---|---|
| 1. Product identification | At least one of GTIN, model number, registered number, serial number, SKU, UPC or alternate identifier, plus a description that matches product to certificate | Item master or product data owner |
| 2. Applicable rules | Each CPSC rule, ban, standard or regulation, listed separately, or the testing exclusion claimed | Product compliance |
| 3. Certifier | Name, street address, city, state or province, country, email and phone of the certifying party | Importer, manufacturer or private labeler |
| 4. Records contact | The individual, or an always-staffed position, keeping the supporting records | Product compliance |
| 5. Manufacture date and place | Month and year at minimum, plus the manufacturer's name, address, email and phone | Supplier |
| 6. Test date and place | Most recent test date and each lab relied on, with full contact details | Supplier or test lab |
| 7. Attestation | The certifier's attestation, carried in the Product Registry and the message set | Certifier |
Bottom line: For a compliance manager supporting 20 or more suppliers, elements 5 and 6 are the gap. They come from the factory and the lab, change with every production run and retest, and arrive in PDFs rather than fields.
Quotable insight: CPSC eFiling turns a certificate from a document into data that has to match the entry line by line. Two of its seven elements, manufacture and test date and place, come from the factory and the lab and change with every run and retest, yet the importer certifies them and stays legally responsible under 16 CFR 1110.15. The filing is the broker's step; the data problem sits in the importer's item master and supplier records, weeks before the goods ship.
The implementation guide also asks for a separate certificate when products are "materially different, meaning that it has a different product design, manufacturing process (including location), or source of component parts (including paints and materials)" [6]. A color variant painted at a second factory is, for this purpose, a second product.
Full PGA Message Set or Reference PGA Message Set: which should you use?
Use the Reference PGA Message Set for products you import repeatedly and the Full PGA Message Set for one-off products. The final rule describes both: with the Full set, "the importer submits all certificate data elements via ACE"; with the Reference set, "the importer enters all certificate data elements into CPSC's Product Registry prior to filing entry with CBP, and then submits a unique reference identifier (ID) via ACE" [1].
| Feature | Reference PGA Message Set | Full PGA Message Set |
|---|---|---|
| Where the seven elements live | CPSC Product Registry, entered before entry | In ACE, sent with each entry |
| PG01 processing code | REF | FGC for a GCC, FCP for a CPC |
| Records sent at entry | OI, PG01, PG02 (Product ID and Version ID), PG14 (Certifier ID) | Can include OI, PG01, PG02, PG07, PG10, PG19 to PG22, PG25, PG30 and PG60 |
| What the broker needs from the importer | Three identifiers per product | All certificate data per product |
| Maintenance | Update the Registry when a retest or new run changes the certificate | Data rebuilt or reused for every entry |
Bottom line: For importers whose catalog repeats entry after entry, the Registry keeps one maintained certificate per product and hands the broker three identifiers. Importers bringing in many one-time products may find the Full set simpler, since nothing has to be registered first.
The implementation guide (version 2.4, May 2026) adds three practical points [6]:
- Methods can be mixed. "Different methods, including a disclaimer message set, may be used for different products imported under the same entry."
- The message set never travels alone. "The PGA Message Set cannot be submitted on its own and must be submitted as part of a valid Automated Commercial Environment (ACE) transmission, such as an entry filing."
- Registry data ages. "Many regulated consumer products require periodic testing and, as a result, the certificate may need to be updated in the Product Registry."
The Full set also carries a hard rule: "Each Full Message Set requires a Manufacturer and at least one of the lab entity options" [6]. The layout sits inside CBP's general PGA Message Set CATAIR, last modified July 6, 2026 [7], explained in more depth in the guide to PGA flags on HTS codes.
Does the CPSC HTS list tell you which products need a certificate?
It tells you where CPSC is looking, not what your obligation is. CPSC's February 6, 2026 bulletin on its updated HTS list for eFiling says approximately 600 HTS codes will be flagged in ACE beginning July 8, 2026, and also that "the list does not encompass all HTS codes that may contain a product requiring an electronic certificate." It adds: "Responsibility for submitting an eFiled certificate, when required, rests with the importer" [10].
That gives two failure modes that run in opposite directions:
- A flagged code, an unregulated product. A disclaimer is optional. The final rule states that CPSC "will not require importers to file a Disclaimer Message Set with CBP for products that do not require a certificate," though it encourages one [1]. If filed, the guide requires an Intended Use Code and allows Disclaim A (no certificate required, including component parts) or Disclaim B (enforcement discretion, with Intended Use Code 130.006 only) [6].
- An unflagged code, a regulated product. No ACE prompt appears, but the certificate obligation still applies. The HTS code routes the line; the product facts decide the requirement.
What happens at entry when the certificate data is missing?
Missing data does not, for now, stop an entry automatically, but it raises the odds of a hold. CPSC answered this directly in the final rule's comment responses: "The lack of a required eFiled certificate, or the presence of a false or misleading certificate, will affect a shipment's risk score, resulting in a higher likelihood of the shipment being held for an exam" [1].
The same response sets the enforcement posture. CPSC "has the authority to refuse admission of products that are not accompanied by a certificate or are accompanied by a false or misleading certificate," citing 15 U.S.C. 2066(a)(2). As a matter of enforcement discretion, "at least in the initial stages of eFiling, CPSC in general does not intend to request that CBP deny entry of products into the United States solely based on a failure to provide eFiled certificate data," while it "fully intends to enforce eFiling requirements by taking enforcement action, such as requesting that CBP initiate seizure of noncompliant products" [1]. CPSC's eFiling FAQ repeats the same position in present tense: "At this time, CPSC does not intend to request that CBP deny entry of products into the U.S. solely based on failure to eFile" [9].
The FAQ also states the other side: certificate data in either message set should "reduce holds and examinations for compliant products" [9]. What a CPSC hold looks like on the ground, and how it differs from a CBP exam, is covered in why CBP holds shipments.
Responsibility does not move with the filing. Under 16 CFR 1110.15, a certifier may rely on another party to enter Registry data but "remains legally responsible for the information in a finished product certificate" [3].
How do you get certificate data ready before the broker asks?
Treat the certificate as a product attribute, kept alongside the HTS code, not as a shipping document. A workable sequence:
- Scope the catalog. For each SKU, record whether a CPSC rule applies, whether it is a children's product under 16 CFR 1200.2, and whether it is a component part.
- Pick GCC or CPC per SKU. Record which, and why, using the four age factors.
- Map each of the seven elements to its owner. Item master, product compliance, supplier, lab.
- Choose Registry or Full set per SKU. Register repeat products; keep the Full set for one-time goods.
- Set triggers for change. A new factory, a new paint or material source, or a retest can mean a new certificate or a new Registry version.
- Hand the broker identifiers, not PDFs. For Registry products, the Product ID, Version ID and Certifier ID per SKU.
Steps 3 and 5 are where volume breaks manual tracking, the same pattern seen in supplier certificate collection. The Form 7501 guide shows where the flagged HTS line sits on the entry summary.
Where certificate data fits in your product records
The eFiling rule rewards importers whose product data changes when the product changes. GingerOS, GingerControl's AI trade compliance platform, watches new rules and changes in your ERP, PLM and supplier records, and alerts you when one affects you. It asks for missing product facts before it suggests an HTS code, and records the reasoning for your approval. GingerControl builds trade compliance AI; it is not a customs broker, importer of record or certifier, does not file entries or PGA Message Sets, and does not give legal advice. The importer certifies, and the licensed broker files.
References
- Consumer Product Safety Commission, Certificates of Compliance, final rule, 90 FR 1800, FR Doc 2024-30826
Data cited: eFiling scope, Full and Reference PGA Message Set definitions, importer definition, Disclaimer Message Set policy, risk score and enforcement discretion (Response 52)
Source: Federal Register, Certificates of Compliance
Published: January 8, 2025 - Consumer Product Safety Commission, Certificates of Compliance; Correction, 90 FR 45917, FR Doc 2025-18521
Data cited: one effective date of July 8, 2026; applicability dates of July 8, 2026 and January 8, 2027 for FTZ entries; no substantive effect
Source: Federal Register, Certificates of Compliance; Correction
Published: September 24, 2025 - Electronic Code of Federal Regulations, 16 CFR part 1110, Certificates of Compliance
Data cited: definitions (1110.3), products required to be certified (1110.5), certifier (1110.7), language (1110.9), content (1110.11), availability and eFiling timing (1110.13), legal responsibility (1110.15), recordkeeping (1110.17), component parts (1110.19)
Source: 16 CFR 1110.13 - Electronic Code of Federal Regulations, 16 CFR 1200.2, Definition of children's product
Data cited: 12 years of age or younger; four statutory factors; label not determinative
Source: 16 CFR 1200.2 - Electronic Code of Federal Regulations, 16 CFR 1107.20, General requirements for children's product testing
Data cited: third party conformity assessment body testing to support certification
Source: 16 CFR 1107.20 - U.S. Customs and Border Protection and CPSC, CATAIR CPSC eFiling Implementation Guide, version 2.4
Data cited: seven data elements, filing methods, REF, FGC and FCP codes, record layouts, ITL rule for CPC, disclaim codes and Intended Use Codes, material difference, Registry updates
Source: CPSC eFiling Implementation Guide v2.4
Published: May 2026 - U.S. Customs and Border Protection, ACE CATAIR PGA Message Set
Data cited: PGA Message Set record layout and guidance page
Source: CBP PGA Message Set
Published: last modified July 6, 2026 - Consumer Product Safety Commission, CPSC Implements Mandatory eFiling for Certificates of Compliance, news release
Data cited: program in effect; FTZ date of January 8, 2027; no new testing, certification or compliance obligations
Source: CPSC news release
Published: July 8, 2026 - Consumer Product Safety Commission, eFiling Frequently Asked Questions
Data cited: no Section 321 exemption; no denial of entry solely for failure to eFile at this time; risk score adjustment
Source: CPSC eFiling FAQ - Consumer Product Safety Commission, Announcement: Updated HTS List for Electronic Filing (eFiling) of Certificates of Compliance
Data cited: approximately 600 HTS codes flagged in ACE from July 8, 2026; list not exhaustive; responsibility rests with the importer
Source: CPSC bulletin on the eFiling HTS list
Published: February 6, 2026
Questions people ask
When did CPSC eFiling become mandatory for a consumer goods importer?
The applicability date for most imports was July 8, 2026, under CPSC's final rule at 90 FR 1800 as corrected by 90 FR 45917. Products imported into a foreign trade zone and then entered for consumption or warehousing have until January 8, 2027. For an importer clearing toys, furniture or apparel every week, every entry of a certified product filed since July 8 needs certificate data in ACE.
How does a compliance manager tell whether a product needs a GCC or a CPC?
Both apply only to finished consumer products subject to a CPSC rule, ban, standard or regulation. A product designed or intended primarily for children 12 or younger needs a Children's Product Certificate, which rests on testing by a CPSC-accepted third party lab. Other covered products need a General Certificate of Conformity. For a home goods importer with a mixed catalog, the age call under 16 CFR 1200.2 decides which certificate each SKU carries.
What certificate data does a customs broker need from the importer before entry?
Either the seven certificate data elements for a Full PGA Message Set, or the Product ID, Version ID and Certifier ID from CPSC's Product Registry for a Reference PGA Message Set. The seven elements are product identification, applicable rules, the certifier, the records contact, manufacture date and place, test date and place, and the attestation. A broker handling 300 lines a week cannot invent any of them.
Is it better for a high-volume importer to use the Product Registry or the full message set?
For SKUs that repeat across many entries, the Product Registry lets the importer enter certificate data once and send a short reference at each entry, so the data is maintained in one place. The Full PGA Message Set suits one-off or low-repeat products. CPSC's implementation guide allows different methods for different products on the same entry, so the choice can be made SKU by SKU.
What happens to a shipment if the CPSC certificate data is missing?
CPSC's FAQ says that at this time it does not intend to ask CBP to deny entry solely for a failure to eFile. The final rule explains that missing data raises the shipment's risk score and the likelihood of an exam, and CPSC keeps the authority to refuse admission and to request seizure of noncompliant products. For an importer, missing data means more holds, not a free pass.
Does CPSC eFiling apply to low-value shipments or component parts?
Low-value shipments are covered: CPSC's FAQ states there is no Section 321 exemption for eFiling. Component parts are not: the rule says component part certificates must not be eFiled, and parts imported for further assembly in the United States, not for sale to consumers, can be disclaimed. For a manufacturer importing both finished goods and parts, the split follows the product, not the shipment.
Does GingerControl file CPSC certificate data or act as the certifier?
No. GingerControl builds trade compliance AI. It is not a customs broker, importer of record or certifier, and it does not file entries, transmit PGA Message Sets or give legal advice. The importer, as finished product certifier, stays legally responsible for certificate data, and the licensed broker transmits it.
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Reviewed by Michael Weick, LCB / CCS
