CPSC eFiling checker
Since July 8, 2026, importers must file certificate of compliance data with CBP for regulated consumer products. Check whether your HTS code is on CPSC's list of codes likely to need certificate data, what the flag means and what to file.
CPSC list dated October 1, 2026: 589 HTS codes, 430 flagged CP1 and 159 flagged CP2. Not legal advice.
What the flags mean
- CP1: certificate related data may be needed
CPSC marks this code as certificate data may be needed: it covers some products that need a certificate and some that do not. File certificate data for products that need one. For the others, CPSC allows an optional disclaim message.
- CP2: certificate related data is required
CPSC marks this code as certificate data required: it expects products under this code to need a certificate. If your product is not subject to any CPSC rule, CPSC allows an optional disclaim message instead.
- Not listed
CPSC says the list does not cover every code where a certificate may be needed. If your product needs a GCC or CPC, eFile it whatever the code.
What you must file
The eFiled certificate carries the seven elements of 16 CFR 1110.11, one product per certificate. A product that differs in design, manufacturing process or location, or component sources needs its own certificate.
- 1Product identificationAt least one unique identifier (GTIN, model number, registered number, serial number, SKU, UPC or another identifier) and a description that matches the product to the certificate.
- 2Rules certified toEach CPSC rule, ban, standard or regulation the product is certified to, listed separately with CPSC citation codes, plus any statutory or regulatory testing exclusion claimed.
- 3CertifierThe importer or domestic manufacturer certifying the product, with name, street address, city, state or province, country, email and phone.
- 4Records contactThe person, or a staffed position, who keeps the test records, with full contact details. A URL to the records is optional.
- 5Date and place of manufactureMonth and year at a minimum, and the manufacturer's name, address, email and phone.
- 6Date and place of testingThe most recent test date and each lab or party whose testing supports the certificate. Children's products need a CPSC-accepted third party lab.
- 7AttestationThe certifier's statement that the product complies and the information is true. For eFiled certificates it is built into the message set and the Product Registry.
How to file
- Full PGA Message Set in ACE
You give your customs broker the certificate data and the broker files it with the entry, or the entry summary certified for release, as the CPSC PGA Message Set.
- CPSC Product Registry and Reference PGA Message Set
You enter the certificate once in CPSC's Product Registry, then give your broker the certificate identifiers. The broker files a short reference message set with each entry. Update the Registry when periodic testing produces a new certificate.
- Disclaim message
For a product under a listed code that needs no certificate, the filer may send an optional disclaim message. CPSC says it may help your risk score.
- Mail shipments
For products imported by mail, the certificate data must be in the Product Registry before the goods arrive.
Deadlines and what happens if data is missing
- July 8, 2026: eFiling required for regulated products entered for consumption or warehousing.
- January 8, 2027: eFiling required for products entered from a foreign trade zone.
- The data is due when the entry is filed, or with the entry summary when both are filed together.
- CBP does not currently reject entries that lack the CPSC message set, even on CP1 or CP2 codes. CPSC may still review the entry, reject the CPSC data, hold the goods and take enforcement action.
Frequently asked questions
What is CPSC eFiling?
Since July 8, 2026, importers of regulated consumer products must file certificate of compliance data electronically with CBP at the time of entry, as part of the CPSC PGA Message Set in ACE. The data come from the General Certificate of Conformity (GCC) or Children's Product Certificate (CPC). The requirement comes from CPSC's final rule amending 16 CFR part 1110, published January 8, 2025. Products entered from a foreign trade zone follow from January 8, 2027.
What do the CP1 and CP2 flags mean?
They are the flags CPSC assigns to HTS codes on its eFiling list. CP1 means CPSC certificate related data may be needed: the code covers some regulated and some unregulated products. CP2 means CPSC certificate related data is required: CPSC expects the products under the code to need a certificate. In both cases you can file an optional disclaim message for a product that needs no certificate.
My HTS code is not on the CPSC list. Do I still need to eFile?
Possibly. CPSC says its HTS list is guidance and not all-encompassing. The duty to certify depends on the product, not the code: if a children's product or a product subject to a CPSC rule, ban, standard or regulation needs a GCC or CPC, its certificate data must be eFiled whatever the HTS code.
Will CBP reject my entry if the CPSC data is missing?
Not at present. CBP CSMS messages of July 8 and July 29, 2026 say CPSC is not asking CBP to reject entries that lack the CPSC message set, even on CP1 or CP2 codes. The filing is still mandatory: CPSC may review the entry, reject the CPSC data in a message to the filer, hold the goods and take enforcement action, including requests to CBP to seize noncompliant products.
Should I file the full message set or use the Product Registry?
Either is allowed and you can choose per product. With the full PGA Message Set, your broker sends all certificate data with each entry. With the Product Registry, you enter the certificate once in CPSC's Registry and your broker files a short reference message set with each entry. The Registry suits products you import repeatedly, and it is the route CPSC requires for mail shipments.
Need the certificate itself?
Draft a GCC or CPC with the data elements CPSC asks for, or classify your product first if you are not sure of the HTS code.