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© SGS Société Générale de Surveillance SA.
© SGS Société Générale de Surveillance SA.
On January 8, 2025, the US Consumer Product Safety Commission (CPSC) published a Final Rule in the Federal Register amending 16 CFR 1110, Certificates of Compliance (CoC). A key element of this update is the introduction of mandatory electronic filing (eFiling) of certificates.
Applicable to all regulated consumer products, mandatory eFiling requires the electronic submission of certificate data through the Automated Commercial Environment (ACE) system of US Customs and Border Protection (CBP). The requirement takes effect on July 8, 2026, or January 8, 2027, for products entering the US from a foreign trade zone (FTZ).
The program covers any consumer product subject to mandatory safety standards and certification, including de minimis shipments. It will significantly reshape how importers, manufacturers and private labelers supply consumer goods to the US. Compliance data, such as product identifiers, manufacturer details, test dates and laboratory information, must be submitted electronically prior to entry. As a result, suppliers will need to update their compliance workflows, ensure the accuracy of certificate data and integrate with the ACE system and the CPSC Product Registry.
For many businesses, these changes may require a fundamental reassessment of supply chain processes, enhanced data management capabilities and a shift toward fully digital compliance practices.
Following our recent webinar, we received many questions that may be helpful to share with you.
Q1 - The CPSC updated the citation/exclusion code file in August 2025. Where can we obtain this update?
The August 2025 version of the eFiling citation and testing exception code file added new citation codes. This document can be found in the CPSC eFiling document library.
Q2 - Will US CBP deny entry of products into the US if importers fail to comply with eFiling?
Based on information provided by the CPSC, the agency does not intend to request that CBP deny entry of products into the US solely on the basis of the importer’s failure to eFile certificate data via a Full Partner Government Agency (PGA) Message Set or a Reference PGA Message Set. Accordingly, the ACE system should send only warning messages and not reject messages for missing PGA data.
However, CPSC will continue to enforce certificate requirements for imported consumer products and may submit requests to CBP to initiate seizure of non-compliant products. Furthermore, CPSC plans to adjust an entry line’s risk score based on certificate data provided via a Full PGA Message Set or a Reference PGA Message Set, which should reduce holds and examinations for compliant products and better focus resources on non-compliant products.
Q3 - Who must file the product and its test results with the CPSC? Is it the manufacturer, the importer, the distributor, the retailer, etc.?
The importer.
Q4 - What is the expected timeframe for the application programming interface (API) solution?
The CPSC has published API specifications for the Product Registry and eFiling system and invited software developers and industry stakeholders to begin integration. These specifications were available even to developers not participating in the pilot stage, allowing API integration work to begin ahead of the voluntary test stage that began in summer 2024, when any importer could choose to begin eFiling. The CPSC has not announced a deadline for ending API applications, but access is provided on a first-come, first-served basis and the number of API applicants is limited according to the CPSC’s development capacity.
Q5 - Can importers integrate directly with the API?
Yes. An importer’s IT department can request a software developer account for API integration purposes. Other importers may also pursue internal API integration.
Q6 - Will replacement parts imported separately and sold directly to the consumer be considered finished products for the purposes of eFiling?
To address the inquiry regarding whether separately imported replacement parts sold directly to consumers qualify as ‘finished products’ for eFiling purposes, the determination hinges on whether such parts meet the regulatory definition of a ‘finished product’ under the 16 CFR 1110 final rule. Under the final rule, a ‘finished product’ is defined as a consumer product (or a component of a consumer product), or any other product or substance, that:
With respect to replacement parts imported individually and sold directly to consumers, because such parts inherently satisfy criteria 2 and 3 – being imported for consumption or warehousing and made available for sale or use by consumers – they will be considered ‘finished products’ if, and only if, they are subject to at least one consumer product safety rule, ban, standard or regulation enforced by the CPSC.
Q7 - Will eFiling mean that brands will not be required to maintain children’s product certificates (CPC) and general certificates of conformity (GCC) internally anymore?
Certifiers must maintain CPC/GCC records for at least five years. The certifier is the party that issues the CoC.
Q8 - What are the certificate identifiers?
Here is an example: suppose the concern is about the reference PGA message set to be eFiled with the ACE system. The reference data for certificate identifiers includes the following three data elements:
Q9 - Can you have more than one manufacturer for each UPC ID number? We use multiple suppliers for each item.
The CPSC considers one product from different manufacturers to be different unique products, as any difference in the manufacturing process is a material change. You must provide separate certificates. Each product can use the same product ID, but each requires a unique version ID.
Q10 - When tested components are used in more than one finished product, will eFiling reference the component results for each corresponding finished product?
Component testing is generally acceptable for chemical requirements. For safety rules requiring finished product testing (e.g. functional or mechanical testing, or accessibility of parts assessment), the finished product must always be tested. For safety rules without such requirements (e.g. total lead content testing), third-party testing of individual components may be acceptable, provided no changes occur after testing.
For example, a toy manufacturer may rely on testing the total lead content of plastic pellets used in injection molding, even if those pellets are used across multiple products. However, finished product testing is still required for small parts and other requirements.
Q11 - How do we ensure the component/fabric testing is captured in the final report? Will the laboratory review the raw material reports to select the appropriate citation while eFiling?
Laboratories must review both component/raw material and final product reports to confirm all regulatory requirements are met and select the appropriate citation for eFiling.
Q12 - Where can I find which items fall under GCC and which items fall under CPC?
Access a list of safety rules requiring a GCC.
Access the list of safety rules requiring a CPC.
Q13 - How often do we need to eFile for an item that is continually being imported throughout the year?
One certificate can cover a product that is manufactured over a period of time. If the same testing covers that batch/shipment, it is not necessary to file again for the new batch. eFiling frequency will generally follow the same frequency as testing.
If the new batch has a material change, or is manufactured at different facilities and/or tested at different laboratories when compared with the original product batch, you must update the eFiling by creating a new version ID.
Q14 - I see that adult-worn apparel can be exempt. Why is children's apparel not exempt under Disclaimer B?
This is because there may be other applicable rules for children’s products, such as 16 CFR 1303 (Ban on Lead-Containing Paint and Certain Consumer Products Bearing Lead-Containing Paint) and 15 USC 1278a (Total Lead Content for Children's Products).
Q15 - How do we know which products qualify for an eFiling disclaimer?
There are two types of disclaimer. You would need to check whether the product belongs to disclaimer A or B.
Disclaimer A:
Disclaimer B:
This would be where the CPSC is exercising implementation discretion and does not require a certificate for a product that has an existing rule, ban, standard or regulation:
Q16 - What is the process for filing a disclaimer?
The process includes two key steps:
With the CPSC’s Final Rule now in place, businesses must prepare their supply chains for mandatory eFiling. SGS SMART, our integrated supply chain management platform, offers a dedicated eFiling module that aligns with CPSC requirements. It automates certificate data collection, reduces manual errors and supports multiple submission formats, including GCC/CPC export, CSV export and direct API submission.
Beyond eFiling, SGS SMART centralizes compliance documentation, monitors product test data against CPSC regulations and delivers timely regulatory updates to help businesses stay compliant. Combined with our global expertise as a CPSC‑approved testing laboratory, SGS SMART enables importers, manufacturers and private labelers to transition smoothly and maintain compliance in the evolving US market.
Learn more about our Hardlines services.
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