WHAT’S THE LATEST

Effective July 8, 2026, the U.S. Consumer Product Safety Commission (CPSC) will require electronic filing (eFiling) of product certificate data for certain regulated consumer goods imported into the United States.

This change does not introduce new safety or testing requirements. It modernizes the import filing process, requiring certificate data to be transmitted electronically through U.S. Customs and Border Protection’s (CBP) Automated Commercial Environment (ACE).

Importers remain responsible for determining applicability, selecting a filing approach, and ensuring accurate certificate data is available at the time of entry. SEKO is monitoring implementation and can support method selection and planning.

 

WHAT WE KNOW

eFiling applies to finished consumer products regulated by CPSC that are subject to a rule, ban, standard, or regulation requiring certification. Not every consumer product is regulated, and not every HTS classification flagged for CPSC requires a certificate in all cases.

In-scope products are identified through two mechanisms:
  1. HTS-based indicators that flag potential CPSC applicability at entry; and
  2. Product-level analysis to confirm whether a specific finished product is subject to a rule requiring certification. 
CPSC’s Regulatory Robot can support this process by helping determine:
  • Whether a product is regulated
  • Which rules apply
  • Whether certification is required
CPSC has established two primary eFiling pathways:
  • Option 1 — Product Registry with Reference Filing
    • Importers upload full certificate data to the CPSC Product Registry in advance, and each entry submits a shortened reference message in CBP’s ACE System linking to that data.
      • Best for: Repeat products, established product catalogs, and importers looking to minimize repetitive data transmission across multiple entries.
  • Option 2 — Full eFiling at Entry
    • The complete certificate data set is transmitted through ACE at the time of entry.
      • Best for: Lower-volume products, unique shipments, or situations where maintaining a registry is not operationally practical.
Applicability, Exceptions, and Responsibility:

HTS indicators alone are not determinative—importer product knowledge remains critical in assessing applicability.

In limited cases, disclaimer filings may be used when an HTS classification is flagged for CPSC, but the product does not require a certificate (e.g., products outside CPSC jurisdiction or covered by a recognized testing exclusion). These filings must be appropriately supported and documented.

Importers remain responsible for certification regardless of who transmits the filing. While brokers may submit eFiling data in ACE, importers must ensure that all certificate information is accurate, complete, and available in a usable format.

 

SEKO'S GUIDANCE

Ahead of the July 8 effective date, SEKO strongly recommends that importers take the following steps:

  1. Identify products that may be in scope using HTS indicators and CPSC tools such as the Regulatory Robot.
  2. Confirm whether certificates are required based on applicable CPSC rules.
  3. Decide on an eFiling strategy — Product Registry vs. full filing — by product or product family.
  4. Engage with SEKO to build an implementation plan aligned with your data readiness, entry volumes, and operations.

SEKO is actively monitoring CPSC and CBP implementation and will provide updates as additional guidance is issued. If you have questions, please reach out to your SEKO representative, or email us at hello@sekologistics.com.

 

Resources

CPSC E-Filing Resources

CPSC Compliance and Testing Resources