The clock is ticking for importers to get ready for mandatory eFiling.

In December 2024, the U.S. Consumer Product Safety Commission approved a final rule to implement electronic filing of certificate information for regulated, imported consumer products and to revise requirements for Certificates of Compliance.

After months of testing the system, mandatory eFiling starts July 8 for all imported consumer products required to file a General Certificate of Conformity or Children’s Product Certificate. Importers will have to electronically file data elements at the time of filing an entry, including:

  • 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.


While it’s expected that eFiling will also reduce inspection frequency and hold times for compliant importers, express carriers like FedEx and UPS have warned of potential shipment delays starting in July. Importers are encouraged to prepare and front‑load shipments where possible.

Key steps to prepare for eFiling:

  • Register your company for the CPSC product registry.
  • 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 whether eFiling is mandatory or voluntary for each of your products.
  • Designate a person or team who owns eFiling for your organization and establish data protocols.


What Products Are Required To Comply With The eFiling Rule?

CPSC’s new eFiling requirement covers a wide range of consumer products, but the rule applies to imported finished goods only. Importantly, e-commerce sales are not exempt.

  • Domestic manufacturers don’t need to eFile but still need to file a GCC or CPC, as applicable.
  • While components and some products are exempt from the requirement, CPSC encourages voluntary eFiling to lower your risk score.
  • CPSC published a list of approximately 600 HTS codes for potentially high-risk product categories likely subject to a mandatory standard. (Note: The list does not encompass all HTS codes where an electronic certificate may be required.)


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.

  • 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.)


How eFiling Works

The data can be entered manually, via CSV batch upload or API integration. There are two methods, and both involve a data set known as a Partner Government Agency Message Set that is transferred between government agencies (in this case, Customs and Border Protection and CPSC):


Your customs broker and testing lab should be able to help navigate this process. Many labs can handle e-filing independently or combined with test requests. CPSC accepts test reports from third-party labs, and your customs broker or testing lab can act as collection administrator, editor or certifier on your behalf.