CPSC eFiling has been mandatory since 8 July 2026, and it changed who has to be organised. Your US importer is the one filing, but every field they file comes out of your factory — the manufacturing address, the month of production, the lab that ran the test, the model number that has to match the one on the carton.
The suppliers getting flagged are not the ones with failing products. They are the ones whose importer had to guess at a field. Below is what CPSC eFiling actually requires, the four beliefs that cause most of the trouble, and the exact data set to hand over before a shipment moves.
What CPSC eFiling is, in one paragraph
CPSC eFiling is the electronic filing of certificate of compliance data with US Customs and Border Protection at the time of entry, using CPSC's Partner Government Agency message set in CBP's Automated Commercial Environment. It applies to finished products subject to any consumer product safety rule the Commission enforces — not only children's products.
The dates are fixed and already behind us:
| Milestone | Date | Source |
|---|---|---|
| Final rule published | 8 January 2025 | Federal Register, "Certificates of Compliance" |
| Effective for CPSC-regulated products generally | 8 July 2026 | Final rule, DATES section |
| Effective for products entered from a foreign trade zone for consumption or warehousing | 8 January 2027 | Final rule, DATES section |
| Codified at | 16 CFR part 1110 | eCFR |
The rule that matters to a supplier is not the filing mechanics — a broker handles those. It is 16 CFR 1110.11, the section that lists what the certificate must contain. Every item on that list is a fact only the factory knows.
Belief 1: "Our test report is the certificate"
A test report is evidence. A certificate is a signed legal statement that the product complies with each rule that applies to it. They are different documents, and eFiling transmits the certificate data, not the report.
Section 1110.11(a) requires each finished product certificate to carry seven things:
| # | Required content | Who actually has it |
|---|---|---|
| 1 | Identification of the product, using at least one unique identifier — GTIN, model number, registered number, serial number, SKU, UPC or alternate identifier — plus a description sufficient to match the product to the certificate | Factory and brand together |
| 2 | Each consumer product safety rule, ban, standard or regulation being certified to, listed separately | Importer, from your product data |
| 3 | The certifier's name, street address, city, state or province, country, email and telephone | Importer |
| 4 | Name and full contact details of the individual maintaining the supporting records (a position title is acceptable if always staffed) | Importer |
| 5 | Date (month and year at minimum) and place of manufacture, including manufacturer name, street address, city, state or province, country, email and telephone | Factory only |
| 6 | Most recent date and place of testing, including full contact details for each third party conformity assessment body the certificate depends on | Factory and lab |
| 7 | The certifier's attestation, with an acknowledgement that a knowingly false statement is a US federal crime | Importer |
Items 5 and 6 are where sample entries stall, because they are the two nobody in the buyer's office can invent. "China" is not a place of manufacture. A lab logo on a PDF is not the lab's street address and telephone number.
Belief 2: "The factory issues the certificate"
For a product manufactured outside the United States, 16 CFR 1110.7(a) makes the importer the finished product certifier. Not the factory. Not the sourcing agent. The importer of record.
That sounds like relief. It is not. The importer signs an attestation that carries criminal exposure for a knowingly false statement, so the importer will push that risk down the chain by contract, by chargeback, or by moving the order. A supplier who can produce all seven fields on request in a consistent format becomes materially easier to buy from than one who answers "we sent the test report already."
There is one exception worth knowing: for a product made in the United States and privately labelled, the private labeler is the certifier unless the manufacturer issues the certificate. It rarely applies to an exporter, and buyers cite it inaccurately often enough that it is worth being the person in the conversation who knows.
Belief 3: "One certificate per shipment"
No. CPSC built the Product Registry specifically so that one certificate can be referenced repeatedly. The same certificate covers repeated shipments of the same product as long as there has been no material change — a change that could affect compliance, such as a different manufacturing facility or a different source of raw materials.
Read that definition as a supplier, because it is a trap disguised as a convenience. Moving one SKU to a second workshop is a material change. Swapping the foam supplier is a material change. Changing the finish on a component is likely one. If you make that change quietly between two orders, your importer's existing certificate is now wrong and neither of you finds out until an entry is reviewed or a product is tested.
CPSC also notes in the rule that certifiers generally test continually manufactured products at least once a year, so an unannounced change is one that can sit undetected for a long time.
The practical rule: tell your importer before a material change, not after. It costs one email and a retest. Not telling costs the certificate.
Belief 4: "Any identifier will do, we'll sort the naming out later"
Rule 1110.11(a)(1) requires at least one unique identifier plus a description good enough to match the physical product to the certificate. That sounds trivial until you look at how one product is named across four documents: a factory model code, a buyer's SKU, a marketplace listing title, and a carton mark. When those drift, the officer reviewing the entry sees a certificate that does not obviously belong to the goods in front of them.
Dimensions are usually the first thing to drift, because they get retyped by hand at every step. A wall cabinet described as 600 mm wide on the certificate, 60 cm on the carton and 23.6 inches on the listing is the same product only if someone does the arithmetic and trusts it. The fix is not more careful typing. It is one measured source: put the actual measured dimensions on the product diagram itself — snap the measurement to the real edge rather than estimating, label each dimension once, then export that same diagram wherever it is needed — so the certificate description, the carton, the spec sheet and the listing all inherit one number. An AI image generator will happily print a dimension that looks right and is not; a diagram driven by measured geometry cannot, because the number is the measurement.
If you sell furniture, that same diagram is what carries the furniture spec diagram work you have already done into the compliance file instead of leaving it in the marketing folder.
Which of your products are actually in scope
Suppliers assume "CPSC" means toys. The scope is any finished product subject to a rule the Commission enforces. For the verticals that read this site, that regularly includes clothing storage units under the tip-over rule discussed in the STURDY Act requirements, cribs and juvenile products including the crib mattress fit requirements, mattresses under the flammability standards, children's furniture, lighters, portable generators, and a long list of children's products that need a Children's Product Certificate rather than a General Certificate of Conformity.
Two certificate types, one filing system:
| General Certificate of Conformity (GCC) | Children's Product Certificate (CPC) | |
|---|---|---|
| Issued under | CPSA section 14(a)(1) | CPSA section 14(a)(2) and 16 CFR part 1107 |
| Applies to | Non-children's products subject to a CPSC rule | Products designed or intended primarily for children 12 and under |
| Testing | As the applicable rule requires | Third party testing by a CPSC-accepted laboratory |
| Same eFiling data set | Yes | Yes |
If you are claiming a statutory or regulatory testing exclusion, the certificate must still list every applicable rule and must identify the exclusion in place of the test date and place. An exclusion is a claim you make on the record, not a gap you leave blank.
The data pack to send your importer
- One unique identifier per SKU (GTIN, model number, SKU or UPC) that matches the carton, the spec sheet and the listing
- Product description with material and measured dimensions, in one unit system, traceable to the same source diagram
- Legal manufacturer name and full street address of the production site, not the trading company's office
- Contact email and telephone for the manufacturing site
- Month and year of manufacture, or the initial date for a run spanning several days
- Test lab name, full street address, email and telephone, for every lab the certificate relies on
- Most recent test date for each applicable rule
- Every applicable rule listed separately, including each ASTM F963 section where toys are involved
- Written notice of any material change — new facility, new raw material source — before the affected order ships
- A named person at your end who owns this file and answers within a working day
FAQ
When did CPSC eFiling become mandatory?
8 July 2026 for CPSC-regulated consumer products and substances required to be certified. Products entered from a foreign trade zone for consumption or warehousing follow on 8 January 2027. Both dates come from the DATES section of the final rule published in the Federal Register on 8 January 2025.
Does the Chinese factory or the US importer file the CPSC certificate?
For goods manufactured outside the United States, 16 CFR 1110.7(a) puts the obligation on the importer, who is the finished product certifier. The factory does not file. The factory supplies the manufacturing and testing facts the filing depends on, and in practice the supply contract pushes the consequences of bad data back to the factory.
Do I need a new certificate for every shipment?
No. The same certificate can be referenced for repeated shipments of the same product as long as there has been no material change — a change that could affect compliance, such as a different manufacturing facility or a different source of raw materials.
How do I stop the certificate, the carton and the listing from disagreeing?
Cut the number of places a specification gets retyped. Keep one measured product diagram as the source, and let the certificate description, the carton mark, the quotation and the listing all take their dimensions from it. Tools built for this measure to the real edge and export the same annotated diagram at whatever size each destination needs, which is a different job from a photo editor that lets you draw an arrow and type any number next to it.
Is a test report enough to satisfy CPSC eFiling?
No. The test report supports the certificate, but eFiling transmits the certificate data set in 16 CFR 1110.11 — product identification, every applicable rule, certifier and records-keeper contact details, date and place of manufacture, date and place of testing, and the attestation.
Sources & References
- Federal Register, 8 January 2025 — CPSC final rule "Certificates of Compliance", including the 8 July 2026 and 8 January 2027 effective dates and the full text of 16 CFR part 1110
- eCFR — 16 CFR part 1110, Certificates of Compliance: who must certify, certificate content, and eFiling format requirements
- eCFR — 16 CFR part 1107, testing and labeling pertaining to product certification for children's products
- 15 U.S.C. 2063 — Consumer Product Safety Act section 14, the certification requirement behind both the GCC and the CPC