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Attention! The US CPSC will implement mandatory consumer electronics filing (eFiling) in 2026, here's the key interpretation!

Time：

2025-12-09

Starting from July 8, 2026, the US Consumer Product Safety Commission (CPSC) requires electronic filing (eFiling) of conformity certificates for imported consumer goods subject to CPSC regulation, including electronic appliances, adult clothing, all children's products, toys, etc.

The US Consumer Product Safety Commission (CPSC) issued a final rule on January 8, 2025. Starting from July 8, 2026, electronic filing (eFiling) of conformity certificates is required for imported consumer goods subject to CPSC supervision, including electronic appliances, adult clothing, all children's products, toys, etc.

Products imported from foreign free trade zones must comply with this regulation before January 8, 2027. The upcoming mandatory electronic declaration requirements will change the process of products entering the US market.

What is CPSC electronic filing?

EFiling is a process introduced by CPSC that requires regulated US consumer goods importers to submit a Certificate of Compliance (COC) electronically. EFiling not only improves the efficiency of CPSC in the supervision of imported goods, but also provides a more optimized and standardized electronic certificate submission process for international trade. Therefore, the specific rules and requirements of eFiling have become a focus of attention for international trade enterprises entering the US consumer goods market. With the formal approval and implementation of the final rules for compliance certificate filing by CPSC, consumer goods exported from China to the US market will face a new round of compliance challenges.

Scope of Application for CPSC Electronic Filing

The new electronic filing system of CPSC will apply to all imported consumer goods (including minimum value goods) subject to mandatory safety standards. If your product needs to be tested or certified according to any regulations of CPSC, the new electronic filing requirements will apply. Including but not limited to the following categories:

electrical appliance
toy
Clothing and footwear
household goods
Youth products
furniture
Seasonal/holiday supplies
Textiles that meet safety standards
Products containing regulated chemicals such as lead and phthalates

Applicable to importers, domestic manufacturers, and private label merchants who need to issue certificates for consumer goods and substances regulated by CPSC that are imported into the United States for consumption, warehousing, or commercial distribution in the United States.

CPSC electronic filing content

Importers of regulated products are required to submit specific data elements (eFiling) electronically upon importation, including:

Product identity information;
Information on the responsible party for compliance certification;
List of consumer product regulations that have been certified for the product;
The manufacturing date and location of the product;
The time and location of the most recent compliance testing of the product;
Test record keeping personnel's contact information.

By using this information, CPSC will improve the efficiency of product inspections and more effectively locate high-risk products imported into the United States. Electronic declaration will also reduce the inspection frequency and waiting time for compliant product importers, reward companies with compliance records, and enable them to import faster.

Common Problems with CPSC Electronic Filing

Q1: Will errors occurring during the voluntary electronic submission phase or voluntary submission of certificate data affect my risk rating or cause shipping delays?

Although the goods still need to undergo routine inspections by the US Consumer Product Safety Commission, errors that occur during the voluntary phase of electronic declaration and voluntary declaration certificate data will not affect the importer's risk score, nor will they cause delays in the goods. The voluntary phase of electronic records aims to support learning and testing without punishing participants for mistakes.

Q2: Do importers need to provide information from all component testing reports when certifying finished products?

Yes, since 2008, detailed information on compliance certificates for all tests has been required to support product compliance certification. Section 14 of the Consumer Product Safety Act (CPSA), Title 15, Sections 2063 (a) and (g) of the United States Code, and Commission regulations (16 CFR Parts 1107, 1109, and 1110) require certificates to provide specific testing information. The testing information on which CPSC regulates product certificates are based includes testing of components when relying on such testing to demonstrate product compliance.

A certificate is a confirmation that the product described on the certificate has undergone all applicable CPSC regulations testing and complies with the listed regulations. Although the committee only requires the issuance of certificates for finished products, all tests used to support compliance confirmation must be recorded on the certificates. Therefore, according to legal requirements, the certificate must state all applicable rules, prohibitions, standards, and regulations; Latest testing date; And identify each testing laboratory that will conduct such testing. The certificate should link each testing laboratory to the specific rules, prohibitions, standards, and regulations they test, whether the testing is conducted on finished products or components, if such testing is used to support compliance confirmation. As of July 8, 2026, the recently revised Part 1110 also requires the determination of any test exclusions relied upon.

Importers should note that all other product testing fields, such as test URL, test report key, and test report ID, are optional, but are encouraged to be provided when submitting the finished product certificate electronically. Please also note that according to the requirements of the US Consumer Product Safety Commission, importers may need to provide supporting testing records and/or information on optional product testing areas.

Q3: If the importer fails to comply with electronic declaration, will the U.S. Customs and Border Protection (CBP) refuse to allow the product to enter the United States?

At present, the US Consumer Product Safety Commission (CPSC) does not intend to require the US Customs and Border Protection (CBP) to prohibit the entry of related products into the United States solely because companies have not submitted certificate data electronically through the "Complete PGA Message Set" or "Reference PGA Message Set". Therefore, CPSC initially does not intend for the Automated Business Environment (ACE) system to send rejection messages due to lack of PGA data, only warning messages.

However, it should be clarified that CPSC will continue to enforce the certificate requirements for imported consumer goods and will submit an application to CBP to initiate seizure procedures for products that do not comply with regulations. In addition, CPSC plans to adjust the risk score of imported goods declaration items based on the certificate data provided by enterprises through the "complete PGA message set" or "reference PGA message set" - this will reduce the frequency of detention and inspection of compliant products, while more effectively concentrating resources on identifying products that do not comply with regulations.

CPSC Compliance Recommendations

Starting from July 8, 2026, CPSC electronic filing requirements will be mandatory. At present, electronic declaration is in the voluntary stage. It is strongly recommended that importers and their trading partners participate in the voluntary stage of electronic declaration, familiarize themselves with the electronic declaration system in advance, and be prepared before the final regulation is fully implemented on July 8, 2026.

As a professional third-party testing and certification service organization, Jiayu Testing has qualifications such as CMA, CNAS, CBTL, CPSC, etc. It has also obtained laboratory accreditation from multiple authoritative certification agencies at home and abroad. The laboratory is strictly built and managed according to standards, equipped with advanced instruments and equipment, and has a skilled professional technical team with rich industry service experience and strong testing technology capabilities. It is proficient in various regulatory standards and provides chemical testing services for consumer goods from CPSC in the United States, assisting enterprises in actively responding to regulatory requirements and effectively improving product compliance. Welcome to contact us at 400-9269-886!