Mandatory eFiling starts next month for many imported consumer products – specifically, items that require a General Certificate of Conformity or Children’s Product Certificate. Importers can no longer submit paper or PDFs and will have to share data elements electronically with the U.S. Consumer Product Safety Commission at the time of filing an entry, starting Wednesday, July 8.

  • Domestic manufacturers do not have to file for domestic products, but they still must comply with current certificate content requirements.
  • Products entering from a foreign trade zone have until January 8, 2027.


The change is significant because certificate data will need to be submitted at entry, not simply kept on hand in case regulators ask for it later. Required elements include:

  • Identification of the finished product.
  • The party certifying compliance.
  • Each consumer product safety rule to which the finished product has been certified.
  • Date and place the finished product was manufactured.
  • When and where the finished product was most recently tested for compliance.
  • Contact information for the person maintaining test records.
  • Full name, physical address and contact information of the manufacturer or private labeler.

Note: This last item is an important new data requirement. Historically, importers only needed to provide the city and country of manufacture.

The data can be submitted in different ways, including manual entry, CSV bulk upload or API integration. Each product must have its own certificate with a unique product ID, and third-party testing is required to support certification. One certificate can cover multiple batches/shipments if there is no material change to the product and the same testing applies.

Key Steps To Prepare For eFiling

  • Designate a person or team who owns eFiling for your organization and establish data protocols.
  • Register your company for the CPSC product registry to store and manage product certificate data.
  • Determine if each of your products needs a General Certificate of Conformity or Children’s Product Certificate. Check Harmonized Tariff Schedule codes as a starting point to identify applicable regulations for your products.
  • Confirm that the testing relied on for certification is current and that any third-party laboratory used for children’s products is appropriately recognized by CPSC.
  • Be sure to use a testing lab that’s on the CPSC accredited list. (Note: Component testing is acceptable for chemical tests, but finished product testing is still required to comply with safety rules.)


Your customs broker and testing lab can help navigate this process, even acting as collection administrator, editor or certifier on your behalf. CPSC accepts test reports from third-party labs, and many labs are able to handle eFiling independently or combined with test requests.

Even if a customs broker, testing laboratory or other trade partner helps with the filing, the importer of record is ultimately responsible for making sure accurate certificate data is submitted. In other words, companies can delegate tasks, but not accountability.

Top Mistakes To Avoid When eFiling

Simple data entry errors and incomplete entries are the most common pitfall when filing in any electronics system, and CPSC eFiling is no different. The system has very specific formatting parameters for elements like phone numbers and other fields. For example, missing the mandated column headers or blank cells in CSV uploads will cause immediate failure for that entire row or batch.


Here are a few other potential eFiling pitfalls to watch out for:

  • Mismatched Certificate Identifiers: Be sure to use the correct Certifier IDs, Product IDs or Version IDs.
  • Updated Product Revisions: A new Version ID is required when a “material change” has been made to a product (like new annual testing data).
  • Incorrect Manufacture Dates: Provide a specific month and year of the initial batch run. 
  • Incomplete Lab Information: Provide the full address and contact information of the CPSC-accepted laboratory that tested the product, as well as the exact date the finished product was tested. 


CPSC eFiling Resources