If you import consumer products regulated by the U.S. Consumer Product Safety Commission (CPSC), a major compliance change is coming on July 8, 2026. Electronic filing of product safety certificate data will become mandatory at the time of entry into the United States.
This new requirement affects thousands of importers, from small businesses bringing in toys and electronics to large distributors handling furniture and appliances. The rule even applies to low-value shipments claiming the Section 321 de minimis exemption (products valued under $800).
Here's what you need to know to prepare for the transition.
What Is CPSC eFiling?
eFiling is a CPSC initiative that requires importers to electronically submit certificate of compliance data through U.S. Customs and Border Protection's (CBP) Automated Commercial Environment (ACE) system using a Partner Government Agency (PGA) Message Set.
Instead of physical certificates or PDF uploads, the system enables CPSC to receive structured, machine-readable data about every regulated product entering the country. This allows CPSC to assess health and safety risks more efficiently and focus inspection resources on higher-risk shipments.
Who Is Affected?
The eFiling requirement applies to:
Importers: Any business importing CPSC-regulated consumer products for consumption, warehousing, or distribution in the United States
Domestic manufacturers: Companies producing regulated products domestically that will be subject to similar requirements in future phases
Private labelers: Businesses whose brand appears on CPSC-regulated products
Low-value shipments: Even products claiming Section 321 de minimis duty exemption (under $800) must comply
CPSC regulates a wide range of consumer products, including toys, electronics, appliances, furniture, childcare products, and more. If you're unsure whether your products fall under CPSC jurisdiction, use the CPSC's Regulatory Robot tool to determine applicable safety requirements.
Key Implementation Dates
The rule takes effect in two phases:
July 8, 2026: Mandatory eFiling for all imports of CPSC-regulated consumer products
January 8, 2027: Mandatory eFiling for products imported from Foreign Trade Zones (FTZ)
The delayed effective date for FTZ shipments provides additional time for importers using these facilities to adapt their processes.
How to Comply: Two Filing Methods
Importers can choose between two methods for submitting certificate data through ACE:
1. Reference PGA Message Set
This approach involves pre-filing certificate data in the CPSC Product Registry. At the time of import, you provide a reference identifier in ACE that links to the pre-filed certificate data.
Benefits of this method:
Faster processing for repeat shipments of the same products
Reduced data entry at the time of import
Easier management of certificates for product lines
2. Full PGA Message Set
With this method, you submit all required certificate data directly in ACE for each entry. This option may work better for importers with highly variable product mixes or infrequent shipments.
Your customs broker will need access to all required data elements to complete the CPSC PGA message set in ACE at the time of entry. Make sure to establish clear communication channels and data sharing processes with your broker well before the July deadline.
Getting Started: The Voluntary Pilot Program
CPSC opened the Product Registry for voluntary participation, allowing companies to register and begin uploading certificate data ahead of the mandatory deadline.
The voluntary pilot program offers several advantages:
Lower compliance risk scores: Early adopters demonstrate proactive compliance
Fewer examinations: Compliant products face reduced inspection rates
Reduced hold times: Pre-filed data speeds clearance for compliant shipments
Cost savings: Fewer delays mean lower storage fees and faster inventory turnover
Self-registration is currently open, but CPSC has capped voluntary participation at 2,000 companies. If you import CPSC-regulated products, registering now is the best way to test your processes before the mandate takes effect.
Essential Steps to Prepare
With less than six months until the mandatory effective date, importers should take action now:
1. Determine Product Coverage
Review your product catalog to identify which items are subject to CPSC regulations. The CPSC has published a preliminary list in its eFiling Document Library, with the final list scheduled for release by July 8, 2026.
2. Register for the CPSC Product Registry
Create your Business Account in the CPSC Product Registry as soon as possible. Early registration guarantees your spot in the voluntary pilot program and gives you time to familiarize yourself with the system before the deadline.
3. Review Certificate Requirements
Ensure your existing certificates of compliance contain all required data elements. CPSC has published the eFiling Quick Start Guide to help importers understand what information must be captured.
4. Coordinate with Your Customs Broker
Your customs broker will be submitting the PGA message set on your behalf. Establish clear processes for sharing certificate data and reference identifiers. Discuss which filing method (Reference or Full PGA Message Set) works best for your business.
5. Update Internal Processes
Integrate eFiling requirements into your import documentation workflows. This may require updates to your procurement systems, communication with suppliers, and training for staff involved in import compliance.
6. Test Your Processes
Use the voluntary period to submit test filings and identify any gaps in your data or processes. CPSC hosts public bi-weekly office hours where you can ask questions and get technical support.
What Happens If You Don't Comply?
Starting July 8, 2026, shipments without proper eFiling data may face:
Customs holds and delays: CBP may place shipments on hold pending certificate submission
Additional examinations: Products without proper eFiling face higher inspection rates
Storage fees: Delayed clearance means accumulating storage charges at ports
Potential refusal of entry: While CPSC initially plans to issue warnings rather than outright rejections, non-compliance could eventually result in denied entry
These consequences can disrupt your supply chain, delay product launches, and increase costs. The financial impact of even a single delayed shipment can far exceed the cost of implementing compliant processes.
Resources and Support
CPSC provides several resources to help importers prepare:
CPSC eFiling website: Central hub for documentation, guides, and updates at cpsc.gov/eFiling
eFiling Quick Start Guide: Step-by-step instructions for getting started with the Product Registry
Regulatory Robot: Online tool to help determine which CPSC requirements apply to your products
eFiling Document Library: Comprehensive collection of reference materials and product lists
Email support: Direct technical assistance at eFilingSupport@cpsc.gov
Bi-weekly office hours: Regular public sessions where you can ask questions and get guidance
How Cubic Can Help
Navigating new compliance requirements can be complex, especially when you're managing multiple product lines and international suppliers. As an AI-native freight forwarder, Cubic streamlines the entire import process, including customs clearance and regulatory compliance.
Our platform integrates with your supply chain to ensure all required documentation, including CPSC certificates, is properly prepared and submitted. We work with you to implement the Reference PGA Message Set approach, pre-filing certificate data and reducing administrative burden at the time of entry.
With Cubic, you get:
Expert guidance on CPSC eFiling requirements
Automated documentation workflows that ensure compliance
Real-time visibility into your shipment status
Proactive alerts about regulatory changes affecting your products
Start Preparing Now
The July 8, 2026 deadline will arrive quickly. Companies that start preparing now will have time to test their processes, identify issues, and make corrections before the mandate takes effect.
Don't wait until the last minute to address this requirement. Register for the CPSC Product Registry today, review your product portfolio, and coordinate with your customs broker to establish compliant processes.
If you need help implementing CPSC eFiling requirements or want to discuss how Cubic can streamline your import compliance, get in touch with our team. We'll help you navigate the transition smoothly and keep your supply chain moving without disruption.
