CPSC Lists Goods That May Require Electronic Compliance Certificates

The Consumer Product Safety Commission has posted to its website a list of about 600 HTSUS numbers that it believes are likely to include products for which certificate of compliance information will have to be submitted electronically beginning July 8. However, this list does not encompass all HTSUS numbers for which an electronic certificate may be required.

The CPSC’s eFiling program will require importers to electronically file data elements at the time of filing an entry, including (1) identification of the finished product, (2) the party certifying compliance, (3) each consumer product safety rule to which the finished product has been certified, (4) the date and place the finished product was manufactured, (5) when and where the finished product was most recently tested for compliance, and (6) contact information for the person maintaining test records.

This requirement will apply to imports of all CPSC-regulated consumer products and substances that require certification, including de minimis shipments. It will become effective July 8, 2026, for all such goods except those imported into a foreign-trade zone and subsequently entered for consumption or warehousing, for which it will become effective Jan. 8, 2027.

The CPSC states that the recently-issued list is intended to help the trade community understand when it and U.S. Customs and Border Protection will coordinate to flag specific HTSUS numbers or when a voluntary disclaim message may be filed, which may benefit an importer’s risk score in the CPSC’s system.

The Commission also encourages the trade community review its 1USG messaging guidance, as any entry with an e-filed certificate will be subject to this process. The CPSC notes that in addition to the products in the list referenced above there are other products that do not need certification but will still go through the 1USG messaging process.

More information about the e-filing process is available here.