From July 8, 2026, the US Consumer Product Safety Commission (CPSC) requires product safety certificate data to be filed electronically with US Customs and Border Protection (CBP) at the moment a shipment enters the country. This article explains who's affected, what data you need to provide, and how to update your commercial invoice so your shipments aren't held at customs.
What's changing
Until now, your General Certificate of Compliance (GCC) or Children's Product Certificate (CPC) only needed to accompany the physical shipment or be available on request. From July 8, 2026, that's no longer enough. The certificate data itself must be submitted electronically to CBP at the time of entry, through the CPSC's Partner Government Agency Message Set in the US Automated Commercial Environment (ACE) system.
Your customs broker or courier transmits this data on your behalf, but you're responsible for supplying it correctly before the shipment arrives.
Note: This requirement applies at all shipment values. There's no minimum threshold — a low-value shipment is subject to eFiling in exactly the same way as a high-value one.
Who this affects
This applies to anyone importing finished consumer products into the US that fall under one of roughly 600 flagged Harmonized Tariff Schedule (HTS) codes. This includes toys, apparel, furniture, batteries, jewelry, mattresses, strollers, and carpets, among other categories.
It applies regardless of:
- Where you're shipping from (UK, China, India, Canada, Australia, or elsewhere)
- The value of the shipment
- Whether you or your customer is listed as the Importer of Record
Note: Shipments under $2,500 that previously cleared through informal consolidated entry will need a separate customs entry once they're subject to eFiling, which may carry additional fees.
Raw materials and components are generally not in scope. Check your product's HTS code against the CPSC flagged list to confirm.
What data you need to provide
You have three options for meeting the eFiling requirement. You only need to use one.
Option 1: Full certificate data (7 elements)
Provide these fields from your GCC or CPC, either in the Remarks field of your commercial invoice or as an attached addendum sheet:
- Product ID
- Applicable CPSC rule(s) — the citation code, e.g. 16 CFR part 1250
- Date of manufacture
- Place of manufacture
- Date of most recent product test
- Testing laboratory (name and contact)
- Records keeper contact information
Option 2: Product Registry identifiers (3 elements)
If you've registered your products in the CPSC Product Registry, you only need to include three short identifiers on your commercial invoice:
- Product ID
- Certifier ID
- Version ID
The Product Registry stores your full certificate data after a one-time setup per SKU. This is the CPSC's recommended option if you ship the same products repeatedly, since it requires far less data on each invoice.
Option 3: A copy of your GCC or CPC
Upload a copy of the certificate with your shipment documents at time of booking, as a PDF or compatible file, or provide a hard copy to your courier at pickup if paperless trade isn't available.
Note: For multi-line shipments with several CPSC-regulated products, each line item needs its own certificate data. If you're shipping three different SKUs on the flagged HTS list, all three need their own referenced data.
How to update your commercial invoice
The required data goes in one of two places on your commercial invoice:
- 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
Easyship generates customs-compliant commercial invoices for every shipment, pre-populated with product descriptions, HTS codes, declared values, and shipping details. You can add your CPSC data in the remarks field without building invoices from scratch.
Steps to prepare
- Check your HTS codes against the CPSC flagged HTS code list to confirm whether eFiling applies to your products.
- Confirm which certificate type applies — a GCC for general consumer products, or a CPC for products designed for children 12 and under.
- Set up a CPSC Product Registry account at cpsc.gov if you ship the same products regularly, so you only need to reference 3 IDs on future invoices.
- Update your commercial invoice template to include space for CPSC data, or prepare a standard addendum sheet.
- Brief your manufacturers and suppliers, since much of the certificate data (manufacturing location, date, testing lab details) comes from them.
- Confirm Power of Attorney status with your customs broker if your CPSC-regulated shipments total over $5,000 in value — this must be on file before shipping.
If your US customer is the Importer of Record
If your customer is listed as the Importer of Record (common with Delivered At Place shipping terms), they're legally responsible for eFiling compliance, but they rely on you to supply the certificate data since you sourced or manufactured the product.
You still need to:
- Provide your GCC or CPC data to your courier or freight partner before the shipment departs
- Include the required CPSC data on your commercial invoice or accompanying documents
Note: If you ship on Delivered Duty Paid (DDP) terms, you're taking on Importer of Record responsibility yourself, and full compliance is your obligation.
What happens if data is missing
Missing eFiling data results in your shipment being held at customs, not a warning. You can expect:
- An "Under Review," "Documents Required," or "Hold Intact" status from CBP
- Delayed clearance while the CPSC reviews and releases the shipment
- Cargo holds or additional physical examinations
- Refusal of release entirely
The Importer of Record is legally responsible for the accuracy of certificate data. Your courier or customs broker can only transmit the data you provide — they can't generate certificates or take on responsibility for their accuracy.
FAQs
Does CPSC eFiling apply to low-value shipments?
Yes. There's no minimum value threshold. Any shipment containing a product under a flagged HTS code requires eFiling, regardless of value.
What's the difference between a GCC and a CPC?
A GCC covers general consumer products. A CPC 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.
Can my courier or customs broker file this on my behalf?
They handle transmission of the data to CBP, but only using the data you supply. They can't generate, certify, or create product compliance certificates for you.
What if my product's HTS code isn't on the CPSC flagged list?
eFiling isn't required for that product, but it may still fall under CPSC safety regulations. Keep a valid GCC or CPC on file in case it's requested.
What is the CPSC Product Registry, and do I need to use it?
It's an online system where you register products and store compliance certificate data. After registering, you receive 3 identifiers to use on invoices instead of the full 7-element data set. It's recommended for high-volume or repeat shipments.
What if my commercial invoice doesn't have space for the required data?
You can provide the data as an addendum sheet attached to the invoice. If you're using the Product Registry, the 3 identifier codes will usually fit in the Remarks field of most standard invoice formats.
Does this apply to shipments from all countries?
Yes. The requirement applies regardless of origin country. What matters is the product's HTS code, not where the shipment is coming from.