Guide · updated 28 October 2026

CPSC eFiling is live — and the FTZ deadline is 8 January 2027

The short answer: since 8 July 2026, CPSC-regulated consumer products entering the United States for consumption or warehousing have had to arrive with their certificate data filed electronically with CBP — not sitting in a folder for an inspector to request. Products entered from a foreign trade zone get until 8 January 2027, which is 72 days from today. If you import into an FTZ and your systems still produce a paper certificate, that is the deadline on your calendar.

The dates that matter

Sources: CPSC final rule, 16 CFR part 1110, published 8 January 2025 (Federal Register document 2024-30826); CPSC eFiling programme pages.

What eFiling actually is

It is not a PDF and it is not an upload portal. Certificate data is filed as a message set with the CBP entry in ACE, at the time the entry — or the entry and entry summary where both are filed together — is lodged. The certificate stops being a document you keep and becomes a field set that has to be correct at the moment of entry. That is why this is an ERP and broker-integration problem for most importers, not a compliance-paperwork problem.

CPSC's own summary of the change is blunt: the certificate data now has to reach the agency before the shipment does.

Who is covered

• Importers of record for any CPSC-regulated product that requires a certificate — children's products, toys, electricals, furniture, flammables and the rest of the regulated list.
• De minimis shipments under Section 321 are in scope. The old assumption that small parcels skip certification does not survive this rule.
• International mail: until 20 January 2027 the mechanism is modified — CBP does not collect entry data for postal shipments, so the certifier enters the certificate data into CPSC’s Product Registry before the shipment arrives, and staff use it to target mail for examination. From 20 January 2027 that changes: CBP’s Entry Type 13 process requires international postal shipments subject to Section 201, 232 or 301 duty, or to PGA jurisdiction, to be filed electronically in ACE for informal entry. Shipments that cannot be filed that way fall back to formal entry — bonding, broker fees and clearance time included. The original 22 October 2026 date was pushed back 90 days by CBP on 14 October 2026.
• FTZ users from 8 January 2027, for goods entered out of the zone for consumption or warehousing.

What has to be in the certificate

The rule fixes the data elements and tightens two of them in ways that catch people out:

1. One product per certificate. Bundles, multipacks and "family" certificates that name several SKUs are not compliant. If you sell a set, it needs its own certificate covering the set as a product.
2. A named person responsible for the records, with contact details — not a department, not a formless "compliance team" mailbox.
3. The product identification, the rule it is certified against, the manufacturer and where the product was made, and the identity of the party holding the test reports.
4. Five-year retention for the certificate and its supporting test records, aligned with CBP's recordkeeping period.

In practice the failure mode is the same every time: the importer can produce a certificate, but cannot produce the lab report and the named recordkeeper behind it within the five-year window, for the exact product version that was entered.

What goes wrong at the border

1. The shipment is held, not rejected. Missing or mismatched certificate data delays release while the shipment sits. Detention cost is charged to the importer, and nobody refunds the demurrage.
2. Broker data drifts from product data. The broker files what you sent them last quarter. Product revisions, new factories and re-branded SKUs do not automatically propagate into the certificate.
3. Compliant products get inspected. CPSC has said that missing data leads to inspections of products that were in fact compliant — the cost lands on the importer either way.
4. Nobody owns the Product Registry account. For mail and de minimis flows this is the whole requirement, and it is frequently nobody's job until the first hold.

Why entries are not being rejected — and why that is a trap

Entries have continued to clear since July, which reads like nothing changed. That is by design, and it is documented. In CSMS #69382435 (29 July 2026) CPSC confirmed that ACE can accept an entry with no CPSC message set at all, or with parts of it missing, provided the overall CATAIR PGA specification is followed. CBP will not reject the entry on that basis.

The rest of the same message is the part that gets skipped. CPSC may respond to trade in an SO message, review the CPSC data on the entry, and reject it — and CPSC may take enforcement action on any entry that lacks required eFiling data. So the absence of a rejection is not evidence of compliance; it is a filing that has not been reviewed yet, on an entry CPSC can still act against. Support for these questions is efilingsupport@cpsc.gov.

What to do this month

1. Ask your broker to show you, in ACE, the certificate data filed against your last five entries. Not the certificate file — the filed message.
2. Map every SKU you import to the CPSC rule it is certified against, and check the certificates are one-product-per-certificate.
3. Name a recordkeeper per certificate and confirm the lab reports exist for that exact product version.
4. If any goods sit in an FTZ, put 8 January 2027 in front of whoever owns the FTZ admission and entry process now — 72 days is not a lot of time to change a systems integration.
5. Check the CPSC Product Registry access before you need it, especially if you ship de minimis or by mail.

Where recall monitoring fits

eFiling proves a product was tested on the day it entered. It does not tell you that the same factory, mould or component has since been recalled — that arrives in the CPSC recall feed, weeks later, usually after customers already have the product. A certificate that was true at entry is not a defence once a recall notice names your product or your supplier's other SKUs.

ShelfWatch reads the CPSC feed daily, filters it to the categories you actually import, and tells you what to do about each notice. The free recall dashboard shows the same data unfiltered.

Related

Entry Type 13 for international mail: the deadline moved to 20 January 2027 — the entry mechanism that carries this certificate data for postal shipments.
Children's Product Certificate (CPC) checklist — who signs it, what has to be on it, and the five fields importers get wrong.
How to check if a product has been recalled — the four official databases.
When a supplier's product is recalled, who pays? — what a recall costs a seller.

Questions

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