The US Consumer Product Safety Commission (CPSC) is moving toward a fully digital compliance environment, and many businesses are still determining what this means for their operations.
On January 8, 2025, the 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 certificate data.
The requirement applies to all regulated consumer products and mandates the electronic submission of certificate data through the US Customs and Border Protection’s (CBP) Automated Commercial Environment (ACE) system. It takes effect on July 8, 2026 for all standard imports of regulated consumer products, 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 market.
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.
To help industry prepare, SGS addresses some of the most frequently asked questions about CPSC eFiling:
Will CBP deny entry of products into the US if importers fail to eFile?
CPSC has indicated that CBP is not expected to deny entry solely due to missing PGA data. The ACE system should send only warning messages and not reject messages for missing PGA data.
However, CPSC will continue to enforce certificate requirements and may request seizure of non-compliant products. Certificate data will also influence risk scoring, potentially reducing holds and examinations for compliant entries and helping better focus resources on non-compliant products.
Who is responsible for filing?
The importer, rather than the manufacturer, distributor or retailer, is responsible for filing product and testing information.
Can importers integrate directly with the application programming interface (API) solution?
Yes. An importer’s IT department can request a software developer account for API integration purposes. 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.
Are separately imported replacement parts sold directly to the consumer considered finished products?
Replacement parts sold directly to consumers are considered ‘finished products’ for eFiling purposes, if they 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:
- Is subject to a consumer product safety rule under the Consumer Product Safety Act (CPSA), or any analogous rule, ban, standard or regulation administered and enforced by the CPSC
- Is imported for the purposes of consumption, warehousing or distribution in commerce
- Is packaged, sold or held for sale to, or for use by, end consumers.
Replacement parts imported individually and sold directly to consumers will be considered ‘finished products’ only if they are subject to at least one consumer product safety rule, ban, standard or regulation enforced by the CPSC.
Does eFiling replace the need to maintain children’s product certificates (CPC)s and general certificates of conformity (GCC)?
No. Certifiers must retain CPC/GCC records for at least five years.
What are certificate identifiers?
The reference data for certificate identifiers includes the following three data elements:
- Certifier ID – created when the importer first establishes a business account; uniquely identifies the importer in the Product Registry
- Product ID – uniquely identifies the product being certified for import (e.g. stock keeping unit (SKU) or universal product code (UPC)
- Version ID – uniquely identifies the version of a product; it can be defined by the importer or randomly generated by the Product Registry
Can one UPC have multiple manufacturers?
The CPSC considers one product from different manufacturers to be different unique products, as any difference in the manufacturing process is a material change. Separate certificates are required: each product can use the same product ID, but each requires a unique version ID.
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.
How do we ensure the component/fabric testing is captured in the final report?
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.
How often must eFiling occur for recurring imports?
One certificate can cover products manufactured over a period of time if the same testing covers that batch or shipment. eFiling frequency will generally follow the same testing frequency. A new version ID is required if there is a material change, new facility or different testing laboratory.
Which products qualify for eFiling disclaimers?
There are two types of disclaimer.
Disclaimer A:
- Products that fall within the CPSC’s jurisdiction, but no rule, ban, standard or regulation requiring a certificate applies
- Products falling outside the CPSC’s jurisdiction
- Products imported as component parts, because eFiling only applies to finished products
Disclaimer B:
Applies 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:
- Adult worn apparel claiming exemption under 16 CFR 1610.1(d)(1) or 1610.1(d)(2)
- Household refrigerators if the product displays an appropriate safety certification mark indicating compliance
SGS solution
With the CPSC’s Final Rule now in effect, companies must prepare their supply chains for mandatory eFiling. SGS SMART, SGS’s integrated supply chain management platform, includes a dedicated eFiling module aligned with CPSC requirements. The system 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 testing data against CPSC regulations and provides timely regulatory updates. Combined with SGS’s global expertise as a CPSC‑approved testing laboratory, the platform helps importers, manufacturers and private labelers transition smoothly into the the new digital compliance era.
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