The U.S. Consumer Product Safety Commission (CPSC) is modernizing how product safety compliance information is collected at the border by implementing a new electronic filing, or eFiling, system for certificates of compliance. This initiative significantly affects importers and manufacturers of children’s products, who must issue Children’s Product Certificates (CPCs) or a General Conformance Certificate (GCC) demonstrating compliance with all applicable safety rules.
As of July 8, 2026, eFiling will shift from a voluntary program into a mandatory part of the import process. The rule requires importers, manufacturers, and private labelers to eFile certificates of compliance for consumer products imported for consumption, warehousing or distribution in the United States.
Products entering from Foreign Trade Zones become subject to the rule starting January 8, 2027. Foreign-trade zones are specially designated sites near U.S. ports of entry that allow corporations of all sizes to move goods in and out of the country paying reduced or no customs duties, taxes, or fees.
Products Requiring a Children’s Product Certificate and eFiling
A CPC is required for any product designed or intended primarily for children 12 years of age or younger. These products must undergo third party testing for certain contaminants such as lead, phthalates and other chemicals at a CPSC accredited laboratory and certify compliance with all applicable safety rules.
Examples include:
- Toys
- Children’s clothing
- Childcare items
- Books and other printed materials
Because all children’s products require CPCs, they also fall under the mandatory eFiling requirement once fully implemented.
eFile Data Requirements
Beginning July 8, 2026, importers must electronically submit a defined set of certificate data elements at the time of entry, not afterward.
These details form the core of what U.S. Customs and Border Protection
(CBP) will use to verify compliance at the border and help prevent noncompliant or unsafe products from entering U.S. commerce.
Required elements include:
- Identification of the finished product
- Identity of the certifying party
- Each applicable consumer product safety rule
- Date and place of manufacture
- Date and place of last testing
- Contact information for the custodian of test records
This information will be submitted through CBP’s Automated Commercial Environment (ACE) system as part of the Partner Government Agency (PGA) Message Set.
The CPSC Product Registry
To support this new process, the CPSC offers a secure online Product Registry where importers can create Business Accounts to store and manage certificate data for transmission through the ACE system. The registry serves as a central repository but does not directly communicate with CBP. It enables importers to maintain and organize their certificate information for efficient filing. The agency encourages early registration as it will be required for filing PGA message sets once mandatory eFiling begins.
Preparing for Compliance
The new rule does not change which products require certification, but it does change how certificate information must be delivered to the government during importation. To ensure readiness, importers of children’s products should start preparing for the eFiling process as the deadline is quickly approaching. Companies should review the requirements of rule at 16 CFR 1110, and the CPSC literature regarding the eFiling process.
Many of the products that require CPCs or GCCs will need either third-party testing or must undergo other testing through a reasonable testing program required by the CPSC, and any such testing will take time before the appropriate certificate of compliance can be issued.
The following steps will ensure a smooth compliance transition:
- Register for a CPSC Product Registry Business Account.
- Audit CPC content to ensure all required elements are present and accurate.
- Coordinate with testing labs to confirm timely availability of necessary testing and documentation.
- Align internal systems with ACE submission requirements for certificate data.
- Train brokers and compliance staff on new mandatory fields and deadlines.
Conclusion
The shift to mandatory electronic filing of CPCs represents a major modernization in how product safety compliance is verified at the U.S. border. Beginning July 8, 2026, importers must be prepared to submit detailed compliance information electronically for every children’s product entry. By preparing early, registering in the Product Registry, updating compliance workflows, and ensuring accurate certificate data, businesses can ensure smooth import operations and avoid costly disruptions.
In this article, Gary Jones, VP EHS Affairs, PRINTING United Alliance, addresses Consumer Product Safety Commission compliance requirements. More information about Consumer Product Safety Commission requirements can be obtained by reaching out to Gary should you have additional questions specific to how these issues may affect your business: gjones@printing.org.
To become a member of PRINTING United Alliance and learn more about how our subject matter experts can assist your company with services and resources such as those mentioned in this article, please contact the Alliance membership team: 888-385-3588 / membership@printing.org.