The U.S. Consumer Product Safety Commission (CPSC) is preparing to implement a significant change to the import process for regulated consumer products. Beginning July 8, 2026, importers will be required to electronically submit product safety certificate information to U.S. Customs and Border Protection (CBP) at the time of entry. For products entered through a Foreign Trade Zone (FTZ), the requirement takes effect Jan. 8, 2027.
The new CPSC eFiling requirements are intended to modernize the import process by helping regulators identify high-risk products, improve examination targeting and facilitate the clearance of compliant goods.
The requirements apply to importers of consumer products that are subject to CPSC safety regulations and certification requirements under the Consumer Product Safety Act and other laws enforced by the CPSC.
What is changing?
Under the new process, importers must electronically file product safety certificate data derived from Certificates of Compliance required under Section 14(a) of the Consumer Product Safety Act.
The required certificate information includes:
- Product identification and description
- Specific regulations with which the product was tested and complies
- Certifier (importer) contact information
- Contact information for the individual maintaining compliance records
- Manufacturing date and location information
- Product testing date and location information, including testing of applicable components
- Importer attestation of compliance
Importers will need to ensure this information is available and can be transmitted electronically as part of the customs entry process.
How importers can prepare
Organizations that import consumer products subject to CPSC oversight should begin evaluating their readiness for the upcoming CPSC eFiling requirements [1].
1. Coordinate filing procedures with customs brokers
Importers should work with their customs brokers to determine how product certificate information will be electronically submitted. Filings can be made through either the Full PGA Message Set or the Reference PGA Message Set.
Establishing a filing process before the compliance deadline may help reduce disruptions once the requirement becomes mandatory.
2. Review product certificate data
Companies should review existing Certificates of Compliance and verify that required data elements are complete, accurate and current. Because certificate information will be used during entry processing, maintaining up-to-date records will be increasingly important.
3. Consider registering for the CPSC Product Registry
Frequent importers of regulated consumer products may benefit from registering for a CPSC Product Registry account.
The Product Registry is a secure online platform used to manage product certificate data. Information maintained in the registry may be used by CBP during entry processing and risk analysis activities.
Organizations that already maintain Product Registry accounts should review their records and confirm that certificate information remains accurate.
4. Review the CPSC HTS guidance list
The CPSC has issued a Harmonized Tariff Schedule (HTS) guidance list [2] to help the trade community identify tariff classifications that may trigger CPSC eFiling requirements.
While the list serves as guidance, reviewing applicable tariff classifications can help importers identify products that may be affected by the new filing obligations.
5. Use available compliance resources
Importers that are uncertain about which CPSC regulations apply to their products can use the CPSC Regulatory Robot [3], an online resource designed to help identify potentially applicable consumer product safety requirements.
Looking ahead
With implementation deadlines approaching, importers should begin assessing product certificate data, filing processes and broker coordination efforts now. Organizations that prepare early will be better positioned to meet the new CPSC eFiling requirements and support a smoother entry process when the mandate takes effect. Failure to provide required certificate information may result in shipment delays, additional CBP or CPSC scrutiny, requests for supporting documentation or other import compliance issues. Importers should work proactively with suppliers and customs brokers to help ensure required data is available before the compliance deadlines.
Organizations that import regulated consumer products should also evaluate how the new requirements may affect their broader compliance and import operations. Baker Tilly's global trade professionals can help assess readiness, identify potential compliance gaps and support implementation planning.
Questions about how CPSC eFiling requirements may affect your organization? Contact our team to discuss your next steps.

