Effective July 8, 2026, any product subject to a rule, ban, standard or regulation enforced by the U.S. Consumer Product Safety Commission (CPSC) must be covered by an electronically filed certificate at the time of entry. While certain Harmonized Tariff Schedule (HTS) codes will begin flagging in our system on July 8 for CPSC requirements, it is important to note that these flags are not exhaustive. Products may still be subject to e-filing requirements even if the HTS code does not flag, depending on the nature of the product. This commonly includes items subject to flammability standards, chemical restrictions (such as phthalates), children’s products for items designed for children 12 years of age and under, and items containing button cell or coin batteries.
For CPSC reporting, entries may be filed using either a full partner government agency (PGA) message set or a reference PGA message set. A full message set includes all required certificate data elements transmitted directly at the time of entry filing. In contrast, a reference message set allows the filer to transmit key identifiers (the certifier ID, product ID and version ID) that link to certificate data already stored in the CPSC product registry. Most filers are expected to use the reference message set, as it is more efficient and reduces data entry by leveraging preregistered product information.
CPSC also recommends including these three identifiers on the commercial invoice or packing list. Including this information can help expedite document reviews and reduce the likelihood of delays.
At this time, CPSC is operating under a voluntary e-filing phase. During this period, errors in submitted data will not impact importer risk scores or cause shipment delays, as the program is intended to support testing and implementation.
Recommended next steps:
- Identifying which of your products are subject to CPSC requirements and what the requirements are (i.e., laboratory testing)
- Confirming whether a General Certificate of Conformity (GCC) or Children’s Product Certificate (CPC) applies
- Establishing a process to manage the product registry and certifier ID, product ID and version ID
- Considering adding the “full message set” or “reference message set” information to your commercial documents
