On January 8, 2025, the U.S. Consumer Product Safety Commission (CPSC) and U.S. Customs and Border Protection (CBP) jointly issued Final Rule 16 CFR 1110, making significant revisions to the compliance certificate requirements for consumer products regulated by the CPSC. The rule clarifies that all compliance certificates must be submitted to CBP electronic filing (eFiling), marking the official entry of U.S. consumer product import compliance into a fully electronic era.

Effective Dates:

The implementation of eFiling will be phased in for two categories of imported products:

• Regulated consumer goods not imported into Free Trade Zones (FTZs): Effective from July 8, 2026;
• Regulated consumer goods imported into Free Trade Zones (FTZs): Effective from January 8, 2027.

eFiling Core Content:

eFiling is an initiative of the CPSC, establishing a dedicated online system, the "CPSC Product Registry", as an independent central database storing product certificate data. Importers are required to submit compliant certificate data elements electronically to CBP's Automated Commercial Environment (ACE) system through a Partner Government Agency (PGA) information set, ensuring real-time data verification upon product entry.

eFiling requires importers to ensure that the submitted certificate data conforms to the format and content standards specified by the CPSC Product Registry online system. All data elements must be consistent with the actual imported product. Products not submitted through eFiling or with incomplete or inaccurate information will face the risk of being refused release by CBP.

The CPSC online product registration system is now fully open. Importers can register a Business Account as soon as possible before the final eFiling rules take effect. By inviting partners (Manufacturers, Laboratories, Points of contact) to jointly manage and certify products in order to prepare for the implementation of eFiling in advance.

Scope of Application

• Responsible Entity: All importers of consumer products regulated by the CPSC
• Certificate Types: Child Product Certificate (CPC), General Compliance Certificate (GCC)

Certificate Data Elements

Finished Product Identification Information; Each Consumer Product Safety Rule for which the finished product has been certified; Time and place of manufacture of the finished product; Time of the most recent compliance test of the finished product; Information of the product compliance certifier; Contact information of the person maintaining the test records.

CTI Service

As a CPSC-recognized third-party testing laboratory, CTI's professional team has officially launched the eFiling platform! It not only provides professional and efficient electronic filing eFiling services, but also builds a complete compliance chain of "testing and certification + electronic filing".

CTI Solutions

▲ Testing and Certification: CTI provides compliance testing for children's products and general products, ensuring compliance with regulatory rules and issuing CPC/GCC compliance certificates, laying a solid data foundation for electronic filing.

▲ eFiling Service: CTI IT team has developed and launched the "CTI eFiling Platform", featuring a unique technical architecture, intelligent data processing, and end-to-end digital services. It intelligently captures and summarizes all information required for eFiling, directly connecting to the CPSC eFiling Product Registry System via API, enabling real-time transmission of batch certificate data elements and certificate updates, achieving efficient and accurate electronic filing of compliance certificates.

CTI Recommendation:

With less than six months until eFiling officially takes effect, we recommend that companies register and certify their products using the CPSC product registration system as soon as possible before it takes effect. CTI can provide professional consulting guidance for eFiling product registration and certification. Contact us to obtain the eFiling guide manual.

About CTI

Established in Shenzhen in 2003, Centre Testing International Group Co., Ltd. (CTI) is China’s leading independent third party testing, inspection & certification company and the first to publicly listed (stock code: 300012). As a market leader, adhering to the core values of “Integrity, Collaboration & Team Advancement, Lean, Innovation, and Customer Centricity”, CTI supports clients as a one-stop solution for testing, inspection, certification, calibration, audit, training & technical services. Our mission is to create trust between regulators, enterprises and end consumers, and we are committed to fulfilling our mission statement to “Building Trust for a Better Life” and ensure healthier, safer, and more sustainable economic development.