CPSC eFiling: What International eCommerce Sellers Must Know Before July 8, 2026

All businesses shipping to the United States are aware of the Certificate of Compliance,  However, from July 8, 2026, it's no longer enough to have your Certificate of Compliance on file. The US CPSC now requires that product safety certificate data be filed electronically with US Customs at the moment your shipment enters the country. 

This applies to any finished consumer product classified under approximately 600 specific harmonized tariff schedule (HTS) codes, regardless of shipment value. Products like toys, apparel, furniture, batteries, jewelry, mattresses, strollers, and carpets are among those in scope. If your products fall under CPSC jurisdiction and the required data isn't present at entry, your shipment will be held.

What is CPSC eFiling?

The Consumer Product Safety Commission (CPSC) is the US federal agency that regulates the safety of consumer products. US federal law has long required manufacturers and importers to test regulated products and certify compliance, through either a General Certificate of Compliance (GCC) for general consumer products, or a Children's Product Certificate (CPC) for products designed for children 12 and under.

Until now, these certificates had to accompany the physical shipment or be available on request. From July 8, 2026, that's no longer sufficient. The certificate data must be submitted electronically with US Customs at the time of entry.

The CPSC transmits this data through the US Automated Commercial Environment (ACE) system via a Partner Government Agency (PGA) Message Set. Your customs broker handles the actual transmission to CBP, but you are responsible for supplying the correct data before the shipment arrives.

Who does this CPSC Regulation Affect?

This applies to anyone importing finished consumer products into the United States where those products fall under one of the ~600 flagged HTS codes. That includes:

• International eCommerce sellers shipping direct to US customers
• Businesses fulfilling orders from overseas factories or third-party manufacturers
• Cross-border sellers importing into the US from any country — the UK, China, India, Canada, Australia, or elsewhere

A few things worth noting:

• The requirement applies at all shipment values — there's no minimum. A $25 children's toy shipment is just as subject to eFiling as a $25,000 pallet.
• Shipments subject to eFiling will require a separate customs entry. If your shipment is under $2,500, it's no longer eligible for informal consolidated clearance, and additional entry fees may apply. (Source: DHL Express CPSC Customer Presentation, May 2026)
• This covers only finished consumer goods. Raw materials or components are generally not in scope, but verify against the CPSC flagged HTS code list.
• For CPSC-regulated shipments with a total value over $5,000 USD, a Power of Attorney must be on file with your customs broker.

Why is the US Making Changes in the CPSC e-Filing Now?

Cross-border eCommerce volumes into the US have grown sharply over the past several years. The CPSC eFiling program was designed to give CBP and the CPSC a real-time, searchable data set to screen shipments before they physically enter the country — faster and more accurately than a paper trail attached to a box.

The eFiling program has been available on a voluntary basis for several years. July 8, 2026 is when it becomes mandatory for all products under flagged HTS codes.

What Data do you Need to Provide Under the CPSC eFiling Requirements?

You have 3 options for providing the required CPSC data:

Full Certificate Data — 7 data elements

Provide the following fields from your GCC or CPC, either directly on your commercial invoice (in the Remarks field or a dedicated column) or as an addendum sheet attached to the invoice:

1. Product ID
2. Applicable CPSC rule(s) — the citation code (e.g., 16 CFR part 1250)
3. Date of manufacture
4. Place of manufacture
5. Date of most recent product test
6. Testing laboratory (name and contact)
7. Records keeper contact information

Product Registry Identifiers — 3 elements (recommended for repeat shipments)

If you've registered your products in the CPSC Product Registry, you only need 3 short identifiers on your commercial invoice:

1. Product ID
2. Certifier ID
3. Version ID

You register each product once in the Product Registry. The system stores the full certificate data. Every future shipment just references the 3 IDs instead of repeating all 7 elements. The CPSC recommends this method for businesses shipping the same SKUs repeatedly, it's faster, requires fewer fields on your invoice, and speeds up the customs entry process.

Copy of the GCC or CPC

Upload a copy of the applicable certificate with your shipment documents at time of booking, as a PDF or compatible file, or provide it in hard copy to your courier at pickup if paperless trade isn't available.

How does Your Commercial Invoice Need to Change?

Your commercial invoice is the document where CPSC data gets recorded. The required information goes in one of two places:

• The Remarks field — for the 7-element full data set or the 3 Product Registry IDs
• An addendum sheet attached to the invoice — if your template doesn't have room for the full data

For multi-line shipments with several CPSC-regulated products, each line item needs its own CPSC data. So if you're shipping 3 different SKUs that are all on the flagged HTS list, all 3 need their own certificate data referenced.

Getting this right is one of the most practical preparations you can make now. 

Easyship automatically generates customs-compliant commercial invoices for every shipment — pre-populated with product descriptions, HTS codes, declared values, and shipping details. 

You can add supplementary notes and reference data in the remarks fields without building invoices from scratch. Every document ships with the shipment, ready for customs. 

Learn more about Easyship's commercial invoice generation 

How Do You Prepare Before July 8, 2026?

Here's a step-by-step breakdown:

Step 1: Check your HTS codes against the CPSC flagged list

Start here: CPSC Flagged HTS Code List (PDF). If your products' HTS codes aren't on the list, eFiling isn't required — though you may still need a valid GCC or CPC on file.

Not sure which HTS codes your products fall under? The CPSC Regulatory Robot can help identify which CPSC safety standards apply to your specific product type.

Step 2: Confirm which certificate type applies

• GCC — for general consumer products subject to CPSC regulations
• CPC — specifically for products designed for children 12 and under, which require testing by a CPSC-accepted third-party laboratory

Step 3: Set up your CPSC Product Registry account

If you ship the same products to the US on a regular basis, set up a business account and register your products now at cpsc.gov/eFiling-CPSC-Product-Registry. This is a one-time setup per SKU. Once done, you use the 3 registry IDs on all future invoices — a fraction of the manual work of the 7-element option.

Step 4: Update your commercial invoice template

Ensure your invoice has space for CPSC data. If not, create a standard addendum sheet template now so it's ready to attach to each shipment.

Step 5: Brief your manufacturers and suppliers

Much of the certificate data — manufacturing location, manufacturing date, testing lab details — comes from your product manufacturer. If your supplier generates invoices or shipping documents on your behalf, they need to know about this requirement and have the relevant data ready to add.

Step 6: Confirm Power of Attorney status with your customs broker

For CPSC-regulated shipments over $5,000 total value, a Power of Attorney must be on file with your customs broker before shipping. If you work with a courier that handles customs on your behalf, check whether this is in place.

What are the Consequences of Not Complying with CPSC eFiling Requirements?

Missing the required CPSC data is a hard stop at customs — not a warning.

If your shipment arrives at US customs after July 8, 2026 without the required eFiling data, you can expect one or more of the following:

• Your shipment receives an "Under Review," "Documents Required," or "Hold Intact" status from CBP
• Final clearance is delayed until the CPSC reviews and releases the shipment — which adds time beyond the standard customs process
• Cargo holds or additional physical examinations
• Refusal of release entirely
• Customs brokers filing entries without the required CPSC data can also be held personally liable by the CPSC (Source: DHL Express CPSC Customer Presentation, May 2026)

The Importer of Record (IOR) is legally responsible for the accuracy of all CPSC certificate data. In most cross-border eCommerce scenarios, that's either the US-based buyer or the selling business, depending on the shipping terms. 

Either way, the courier or customs broker can only transmit the data you provide, they can't generate certificates or assume responsibility for their accuracy.

What if Your US buyer is the Importer of Record?

For cross-border sellers, this situation needs some thought.

If your US customer is listed as the Importer of Record, common in Delivered At Place (DAP) or similar arrangements, they're legally responsible for eFiling compliance. But they depend on you to supply the certificate data, since you're the one who sourced or manufactured the product.

In practice, this means:

• You need to provide the GCC (General Certificate of Conformity ) or CPC (Children's Product Certificate ) data to your courier or freight partner before the shipment departs
• Your commercial invoice or accompanying docs must include the required CPSC data, even if the buyer is the IOR

If you ship on Delivered Duty Paid (DDP) terms, where you handle customs clearance on the buyer's behalf, you're taking on the IOR responsibility yourself. Full compliance is your obligation.

Getting import costs right matters here too. When you're calculating what it costs to land a product in the US, duties and taxes are part of the equation — and unexpected customs costs create friction for both you and your buyers. Easyship's duties and taxes calculator gives you a full landed cost breakdown before you ship, so you can quote customers accurately and avoid surprises at the border. 

Calculate duties and taxes with Easyship →

Frequently Asked Questions

Does CPSC eFiling apply to low-value shipments?

Yes. There's no minimum value threshold. Any shipment containing a product classified under a flagged HTS code requires eFiling, regardless of how much it's worth. Shipments under $2,500 that previously cleared through informal consolidated entry will now need a separate customs entry, which may carry additional fees. (Source: DHL Express CPSC Customer Presentation, May 2026)

What's the difference between a GCC and a CPC?

A GCC (General Certificate of Compliance) covers general consumer products regulated under CPSC. A CPC (Children's Product Certificate) is specifically for products designed for children 12 and under, and requires testing by a CPSC-accepted third-party laboratory. Both contain the same 7 core data elements required for eFiling. Sample documents are available at CPSC.gov.

Can my courier or customs broker submit the eFiling on my behalf?

Your customs broker or courier handles the transmission of eFiling data to CBP — but only using the data you supply. They cannot generate, certify, or create product compliance certificates. You are responsible for providing accurate, complete certificate data before or at the time of entry.

What if my product's HTS code is not on the CPSC flagged list?

eFiling is not required for that product. However, your product may still fall under CPSC safety regulations, and you should keep a valid GCC or CPC on file in case it's requested. Use the CPSC Regulatory Robot to check which standards apply to your products.

What is the CPSC Product Registry and do I need to use it?

The CPSC Product Registry is an online system where businesses register products and store their compliance certificate data. After registering a product, you receive 3 identifiers (Product ID, Certifier ID, Version ID) to use on commercial invoices going forward — instead of the full 7-element data set. The CPSC recommends it for high-volume and repeat shipments because it reduces the amount of data required per invoice and speeds up entry. Create a business account at cpsc.gov/eFiling-CPSC-Product-Registry.

What if my commercial invoice doesn't have space for all the required data?

You can provide CPSC data as an addendum sheet attached to the invoice. If you're using the Product Registry, the 3 short identifier codes can fit in the Remarks field of most standard invoice formats.

Does CPSC eFiling apply to shipments from all countries?

Yes. The requirement applies to all US import shipments regardless of origin country. The trigger is the product's HTS code and whether it falls on the CPSC flagged list — not where the shipment comes from.

What if the required information changes between shipments — for example, a new manufacturing batch?

You'll need to update your certificates and, if you're using the Product Registry, update the registered product data to reflect the new manufacturing information. The CPSC requires that certificate data be accurate and current. Maintain updated CPC/GCC documentation each time a manufacturing batch changes.

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