Many imported consumer products now require eFiling at the time of entry – specifically, those that must provide a General Certificate of Conformity or Children’s Product Certificate to the U.S. Consumer Product Safety Commission. Since July 8, importers can no longer submit these documents using paper or PDFs and have to submit data elements electronically.
Imports received by mail will soon also be required to eFile. Beginning October 22, 2026, consumer products imported by mail that are subject to CPC and GCC requirements must also enter the required certificate data electronically in the Automated Commercial Environment.
- CPSC created the new designation Entry Type 13 to enable eFiling for these shipments after implementing an indefinite suspension of the de minimis exemption for imports valued at $800 or less arriving through the international postal network.
- The process and requirements are the same; only the scope of eFiling has expanded.
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Certificate data must 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.
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.
It’s also important to remember that even though eFiling is not required for domestic products, CPCs and GCCs for these products now need to include the following attestation:
- I hereby certify that the finished product(s) covered by this certificate comply with the rules, bans, standards, and regulations stated herein, and that the information in this certificate is true and accurate to the best of my knowledge, information, and belief. I understand and acknowledge that it is a United States federal crime to knowingly and willfully make any materially false, fictitious, or fraudulent statement, representation, or omission on this certificate.
Risks of non-compliance are significant, with potential cargo holds up to 60 days (storage paid by the importer) and penalties up to $120,000 per violation. Errors can lead to an elevated CPSC risk score, triggering more frequent inspections in the future.
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Although the CPSC has so far issued warnings but not rejections so far, it’s important to remember that release of an entry does not guarantee compliance. Enforcement can follow after release, including seizure, recalls and redelivery orders even after goods are sold. “‘Warning, not reject’ is not the same as ‘safe,’” writes Jennifer Diaz, a board-certified international attorney specializing in customs and international trade.
PPAI has not heard from any members experiencing significant eFiling problems so far. Please contact Rachel Zoch, CAS, PPAI’s public affairs manager, at rachelz@ppai.org if you have any questions about regulatory issues or government affairs.
