Compliance guide
CPSC eFiling for ecommerce sellers
Consumer goods now carry a certificate filing at the moment of entry. Here is what the rule asks for, what your broker needs from you, and when to get it.
Written by Borderless CHB. A licensed broker (Joy Xue, CBP filer code NQR) confirms classification before any entry is filed · Updated
The short answer: since July 8, 2026, an importer of a CPSC-regulated finished consumer product has to transmit certificate data to CBP electronically as part of the entry. Not the certificate PDF. The data elements off it, sent in CPSC's PGA message set. Goods entered for consumption or warehousing out of a foreign trade zone are phased in on January 8, 2027.
Who this applies to
You, if you are the importer of record on finished consumer products that fall under a CPSC rule. The sales channel is irrelevant. Amazon FBA inventory, a Shopify store's stock, TikTok Shop goods, and a wholesale container all clear customs the same way. Value is irrelevant too. The rule states that de minimis shipments carrying regulated finished products still have to file the message set, through an entry type capable of carrying it (currently entry type 86).
Scope follows the safety rule, not the tariff number. If a finished product is subject to a consumer product safety rule, ban, standard, or other regulation the Commission enforces, it needs a certificate, and that certificate's data has to be filed. The practical question is always about the product rather than the code.
CPC or GCC
Two certificates, two different tests behind them. On an imported product the importer issues it, not the factory.
| Certificate | Covers | Testing behind it |
|---|---|---|
| Children's Product Certificate (CPC) | A finished product designed or intended primarily for children 12 and under that is subject to a children's product safety rule. Toys, children's apparel, cribs, children's sleepwear. | Must be based on testing by a CPSC-accepted third-party laboratory. |
| General Certificate of Conformity (GCC) | A general-use finished product subject to a CPSC rule, ban, or standard. Mattresses, adult bicycle helmets, adult clothing under the flammability standard. | Based on a test of each product or on a reasonable testing program. No third-party lab required. |
What your broker needs from you
A certificate is a set of facts, and every one of them has to reach the entry. This is the list from 16 CFR 1110.11:
- An identifier for the product (GTIN, model number, SKU, UPC, or similar) plus a description good enough to match it to the certificate.
- Each safety rule, ban, standard, or regulation the product is certified to, listed separately.
- The certifier's name, street address, city, state or province, country, email, and phone. On an import that is you.
- Contact details for the person who keeps the underlying test records.
- The month and year of manufacture and where it happened, with the manufacturer's name and address.
- The most recent date the product was tested for compliance and where the testing took place.
- The third-party conformity assessment body, on a children's product that requires one.
- The attestation itself, the statement that the product complies and the information is accurate.
There are two ways that data reaches CBP. In the full message set, the broker transmits every element with the entry. In the reference message set, you load the elements into CPSC's Product Registry ahead of time and the entry carries a unique reference ID instead. Mail shipments go into the Product Registry before the goods arrive.
What happens when the data is missing
The message set is part of the entry, so an entry without it is not a complete filing, and the freight waits while you chase a lab report or a factory address. That is the real exposure here. A missing test cannot be backdated, and a test takes as long as it takes, so a shipment can sit at the port for weeks over a data element nobody collected at the purchase order stage.
How Borderless handles it
Upload the certificate, or the test report plus the manufacturer details, into theclient portalalongside the commercial invoice and packing list. We take the data elements off it, classify the goods, and file the CPSC message set with the entry. You review the draft entry and confirm the duties before anything is transmitted.
The better moment to ask is before the goods ship. Send us the product and we will tell you whether it needs a CPC or a GCC and what has to be in hand by entry. Entries are $149 flat pay as you go with ISF bundled, and a new importer's first formal entry is $99 all-in. The rest of the rate card is on thepricing page.
Common questions
Do I have to send CBP a copy of my CPC or GCC?
No. The rule requires the certificate data elements, transmitted electronically in CPSC's PGA message set as part of the entry. The certificate itself still has to exist, has to be kept on file, and has to be furnished on request. CBP is not collecting the PDF at the border.
Does this apply to small parcels and de minimis shipments?
Yes. Value buys no exemption. The final rule requires de minimis shipments containing CPSC-regulated finished products to file the PGA message set through an entry type capable of transmitting it, which is currently entry type 86.
Who issues the certificate if my factory is overseas?
You do. Under 16 CFR 1110.7 the importer is the finished product certifier for a product manufactured outside the United States. Your factory supplies the manufacturing and testing facts. The certificate is yours to issue and yours to stand behind.
Can my customs broker write the certificate for me?
No. The certifier is the importer, not the broker. Borderless files the certificate data you supply with the entry and tells you what is missing before anything is transmitted, but the testing and the attestation belong to you.
Sources
- CPSC, Certificates of Compliance, final rule, 90 FR 1800 (January 8, 2025) · effective July 8, 2026; applicable July 8, 2026, and January 8, 2027 for goods entered from a foreign trade zone; PGA message set, Product Registry, and de minimis treatment.
- CPSC, Certificates of Compliance; Correction, 90 FR 45917 (September 24, 2025) · one effective date, separate applicability dates.
- 16 CFR 1110.11 · required content of a finished product certificate.
- 16 CFR 1110.7 · the importer is the finished product certifier on imported goods.
- 15 U.S.C. 2063 · general conformity certification, and third-party testing for children's products.
Importing consumer goods this season?
Send us the product and the origin. We'll tell you what CPSC data your entry needs before the freight books.