eFiling – CPSC’s Modern Approach for Filing Certificate Data

Gaining familiarity with the resources available on our webpage and in our Document Library such as our eFiling Quick Start Guide and Product Registry Training Videos is an excellent way to kick off participation in the eFiling voluntary stage. 

While shipments are still subject to usual CPSC examination, participation in the eFiling voluntary stage and mistakes made in voluntary filings of certificate data will not impact importers’ risk scores nor cause shipment delays. The eFiling voluntary stage is designed to support learning and testing without penalizing participants for mistakes.

Yes, since 2008, providing details on a certificate of compliance regarding all testing done to support certification of product compliance has been required.  Section 14 of the Consumer Product Safety Act (CPSA), 15 U.S.C. § 2063(a) and (g), and the Commission’s regulations (16 C.F.R. parts 1107, 1109, and 1110), require that certificates provide specific testing information upon which the certificate for a CPSC-regulated product depends, which includes testing done on component parts when such testing is relied upon to certify the product’s compliance. 

A certificate is an affirmation that the product described on the certificate was tested to all applicable CPSC regulations and is compliant with the listed regulations.  Although the Commission only requires certificates to be issued for finished products, all testing used to support this affirmation of compliance must be recorded on the certificate.  Accordingly, as required by law, certificates must state all applicable rules, bans, standards, and regulations; the most recent date of testing; and identify each testing lab that conducted such testing.  Certificates should associate each test lab with the specific rules, bans, standards, and regulations for which they tested, regardless of whether the test was conducted on the finished product or a component part, if such testing is being used to support the affirmation of compliance.  As of July 8, 2026, the recently revised part 1110 also requires identification of any testing exclusions relied upon. 

Importers should note that all other product testing fields such as Test URL, Test Report Key, and Test Report ID are optional, but encouraged, to provide when eFiling a finished product certificate.  Please also note that importers may be required to provide supporting test records and/or information regarding optional product testing fields upon CPSC request.

At this time, CPSC does not intend to request that CBP deny entry of products into the U.S. solely based on failure to eFile certificate data via a Full PGA Message Set or a Reference PGA Message Set. To this end, CPSC does not intend initially to have the ACE system send reject messages for missing PGA data, only warning messages. However, CPSC will continue to enforce certificate requirements for imported consumer products and submit requests to CBP to initiate seizure of non-compliant products. Furthermore, CPSC intends 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. 

For further guidance, please see the Federal Register Notice for Certificates of Compliance. 

The Product ID uniquely identifies the product being certified. The Product ID must be one of seven possible alphanumeric ID types:  

• GTIN (Global Trade Item Number)
• SKU (Stock Keeping Unit)
• UPC (Universal Product Code)
• Model Number
• Serial Number
• Registered Number
• Alternate ID* 

*An Alternate ID can be any alphanumeric ID not covered by the other six provided Product ID types.  

Users should not store any data in product identifier fields that does not directly correspond to the chosen identifier type. While the “Alternate ID” type is provided to allow users to store product identifiers not represented by the other six options, the field should still only include identifying information for an individual product. 

More information is available in the Product Registry User Guide and the eFiling Quick Start Guide.

The Product ID is one of three required Certificate Identifiers that are required to identify a specific product certificate stored in the Product Registry. The Certificate Identifiers must be provided when transmitting Reference PGA Message Sets in U.S. Customs and Border Protection’s (CBP) Automated Commercial Environment (ACE) system to accurately reference the applicable product certificate stored in the user’s Product Registry Business Account. 

CPSC strongly recommends that users provide at least one product identifier that can be found on the product packaging, product packing list, and/or on the product invoice to ensure the product can be identified by CPSC personnel. 

The Primary Product ID is the product identifier that is used as the “Product ID” Certificate Identifier when filing a Reference PGA Message Set. It also functions as the “key” that enables users to update existing certificate entries stored in a Product Collection when used in combination with the “Version ID” field. After a user provides a Primary Product ID for a product certificate, it is possible to add additional Product IDs if they are a different ID type from the Primary Product ID. Users may choose to provide additional Product IDs to support their product tracking within specific product collections in CPSC’s Product Registry.

Once participants progress into phase three of the voluntary stage and are ready to transmit Partner Government Agency (PGA) Message Sets, they can transmit using one of two methods:  

• Full PGA Message Set: The importer provides their broker with the seven required product certificate data elements for the imported product and the broker files it in the CPSC PGA Message Set. The required data elements include the Product ID, Citation Codes, Manufacture Date, Manufacture Place, Product Test Date, Testing Laboratory, and Point of Contact.
• Reference PGA Message Set: The importer pre-enters the product certificate data into the CPSC Product Registry and then provides their broker with the Certificate Identifiers to be filed in the PGA Message Set. The Certificate Identifiers are the Certifier ID, Product ID, and Version ID.

Yes, the Product Registry has a Trade Party Privacy setting that Business Account Administrators can enable to restrict the visibility of trade party data stored within their account. Within the context of the Product Registry, “trade parties” refers to the manufacturers, testing laboratories, and points of contact that are required to be identified on valid certificates of compliance. 

To enable Trade Party Privacy, a Business Account Administrator must turn the privacy setting “On” for a new Product Collection at the time it is created. When Trade Party Privacy is enabled on a collection, all trade party data added to that collection will only be visible to users that have been granted a role within that specific collection. 

Product Collections that have Trade Party Privacy set to “Off” all use a single “shared” trade party list. Business Account Administrators should think carefully about how they would like to structure their Product Collections to ensure that the visibility of their trade party data aligns with their business needs. 

Additional points to keep in mind related to Trade Party Privacy are: 

• The Trade Party Privacy setting cannot be toggled on or off after a Product Collection has been created.
• Product certificates cannot be copied into or out of collections with Trade Party Privacy enabled.
• Only Business Account Administrators can add a new trade party to multiple private Product Collections at the same time.
• For collections with privacy enabled, the uniqueness of Alternate IDs and Global Location Numbers (GLN) is only validated against the trade parties stored within that specific collection. 

Reference PGA Message Sets are preferable if the importer repeatedly imports regulated consumer products covered by the same product certificates. By using the Product Registry, the importer can leverage manual or bulk upload features to file product certificate data in a streamlined and more efficient manner. As long as the product certificate details are identical, a product certificate can be entered in the Product Registry and referenced repeatedly as multiple shipments of the same product are imported.

No, the CPSC Product Registry serves as a stand-alone central data repository for importers’ product certificate data and does not communicate with CBP’s ACE system. Once a product certificate is entered and certified in the Product Registry, importers must communicate the three Certificate Identifiers from the product certificate to their broker, so that the Reference PGA Message Set can accurately reference the applicable product certificate in the Product Registry.

No, the CPSC Product Registry is not required to file Full PGA Message Sets.

Users have two options to bulk upload product certificate data into the Product Registry. Users can bulk upload via a Comma-Separated Values (CSV) file or Application Programming Interface (API) integration. Users can access our CSV Bulk Upload Template, User Guide for CSV Upload, and API Specifications document in the Document Library available on our webpage for additional guidance.

Participants are encouraged to review the HTS, Citation, and Testing Exclusion codes in our Document Library to best understand which codes require product certification and/or if a Disclaim is allowed. The HTS, citation, and testing exclusion codes available in our Document Library are not all-encompassing lists and only serve as guidance for the eFiling voluntary stage. For additional citation and testing exclusion guidance, we encourage you to use our Regulatory Robot and/or reach out to CPSC’s Small Business Ombudsman team at sbo@cpsc.gov. For additional guidance on HTS codes, we encourage you to work with CBP and your trade partners to better understand the HTS codes that apply to your products.

CPSC will not be flagging HTS codes for CPSC data review during the eFiling voluntary stage.  

CPSC will be flagging HTS codes for CPSC data review upon eFiling full implementation.

If the product requires product certification and a testing exclusion applies, then a testing exclusion code must be provided with the product certificate. The Product Registry includes a feature that allows users to add testing exclusion codes.

You can contact the eFiling support team via the eFiling Support Inbox at eFilingSupport@cpsc.gov.

No, Disclaim PGA Message Sets are not required. CPSC encourages importers to file Disclaim PGA Message Sets for the benefit of potentially improving their risk score.

CPSC has approved a Final Rule to implement eFiling of Certificate information for imported, regulated consumer products. Under the Final Rule, requirements impacting most imported consumer products will take effect on July 8th, 2026. Requirements impacting consumer products imported into a Foreign Trade Zone (FTZ) and subsequently entered for consumption or warehousing will take effect on January 8th, 2027. Learn more about eFiling full implementation by viewing our CPSC News Release and the Federal Register Notice.

The importer is required to submit certificate data at the time of filing entry in Customs and Border Protection’s (CBP) Automated Commercial Environment (ACE) for all merchandise withdrawn from a Foreign Trade Zone (FTZ) for consumption or warehousing. Additionally, CPSC’s final rule provides a 24-month implementation period, with an effective date on January 8th, 2027, for merchandise entered from an FTZ. This extended timeframe provides the trade with ample time to apply necessary software updates or business operation changes to comply with CPSC’s new requirements for products entered from an FTZ.

ACE already has the functionality to accept the requisite certificate data via the CPSC message set on a type 06 consumption entry for merchandise withdrawn from an FTZ. The CPSC message set can also be transmitted as part of a weekly entry submission.

View the eFiling Guidance for Foreign Trade Zones.

Any product requiring certification must have an eFiled certificate, regardless of the value of the imported shipment. There is no Section 321 (also known as de minimis) shipment exemption for eFiling. 

Please note that Disclaim PGA Message Sets are not required for any imported shipments, including Section 321 (de minimis) shipments but CPSC encourages importers to file Disclaim PGA Message Sets for the benefit of potentially improving their risk score.

A CPSC Reference PGA Message Set requires an entry and therefore cannot be attached to a CBP manifest.

CPSC does not notify the trade of HTS code updates. CPSC is advising the trade to check the U.S. International Trade Commission (ITC) website for HTS code updates.

CPSC highly encourages importers to consider participating in the eFiling voluntary stage to be better prepared for full implementation. The eFiling voluntary stage is for importers and their trade partners to initiate the learning process, assess program readiness, and slowly ramp up eFiling testing efforts. We anticipate an initial learning curve but by progressing through each implementation phase, importers and their trade partners will be able to minimize mistakes and eFile for more products over time as they prepare for eFiling’s full implementation.

Participants can eFile for as many products as they choose. Participants can start small and build out their portfolio of products for eFiling over time.